The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Sellafield site licensee (Sellafield Limited, SL) against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Programme. In accordance with that strategy, a Licence Condition (LC) compliance inspection of the Plutonium Finishing and Storage (PF&S OU) was carried out, as planned, in July 2016.
The purpose of this planned inspection was for the ONR to determine the adequacy of implementation of the licensee's formal arrangements for compliance with LC 7 (incidents at the site). For the inspection, I focused on the evidence of compliance within the Plutonium Management Facility (South) as the plants control a significant hazard on site and it is important the licensee is capable of minimising the probability of events reoccurring, as well as maximising learning from any events that do occur.
LC 7 requires that the licensee makes and implements adequate arrangements for the notification, recording, investigation and reporting of incidents on the site.
On 14 July 2016, I carried out a one-day, on-site LC 7 compliance inspection within the PF&S OU, specifically focused on plants that form the PMF(S) group. The inspection comprised discussions with SL staff and reviews of plant records and other documentation. As part of my preparation for the delivery of this intervention, the following formal ONR guidance documentation was used:
This was not a system based inspection, and therefore no judgement has been made of the adequacy of implementation of any part of the safety case.
During my inspection, I sampled the delivery of event trending for the PMF(S) plants, specifically focusing on the quality and impact of the periodic assessment the information collected and how effectively this was used to deliver changes in the management of the plants. In my opinion, the licensee has implemented their arrangements for compliance adequately, but has failed to take full benefit from the information identified as part of the trending activities, and thus has lost some learning from experience (LFE) opportunities to improve safety and operational performance.
I also sampled the effectiveness of internal investigations conducted by the licensee over the last 12 months. In my opinion, the licensee has not fully implemented their arrangements for compliance, as there was evidence of failure to conduct investigations in a robust and self-challenging manner, and evidence that corrective actions (to reduce the likelihood of re-occurrence) had not been delivered in a timely manner.
Therefore, I also reviewed the timely delivery of all extant event-related corrective actions within the licensee's management system. I consider that, until this last month (June 2016), actions were not being delivered in a timely manner. I believe this may be due partly to the use of the management system to manage activities that would be better controlled using other site processes, and that the licensee has not fully implemented their arrangements for the effective identification, tracking, completion and confirmation of delivered benefit against all event related actions. I noted, however, that key personnel within the PMF(S) leadership team have changed over the last four weeks and that the licensee, with challenge and support from their internal regulator, has already identified these issues and is starting to deliver a number of short-term actions to address the shortfalls I have summarised above.
From those areas sampled, I did not identify any significant shortfalls in the licensee's formal arrangements for compliance which would prompt an inspection of those arrangements earlier than currently planned.
I consider that there is evidence of significant shortfalls against relevant good practice, when compared against an appropriate benchmark. Therefore, with regard to compliance against compliance with Licence Condition 7, it is my opinion that a rating of Amber (seek improvement) is merited. I have raised ONR Regulatory Issue 4617 to record my formal enforcement communication and to track the licensee's progress in addressing these shortfalls in a timely manner.
From the evidence sampled during these inspections, I judge that there was sufficient evidence that the licensee's formal arrangements for compliance with Licence Condition 7 are not being implemented adequately. My findings and conclusions were discussed with and accepted by the licensee.