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, this planned Licence Condition (LC) compliance inspection in the Decommissioning Directorate was carried out in August 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 17 (Management Systems). I focused on the evidence of compliance within the Decommissioning Directorate, as this sets the expectation and direction of the four Legacy Ponds and Silos (LP&S) programmes which are a major part of the High Hazard and Risk Reduction programme at SL.
LC 17 requires the licensee to establish and implement Management Systems which give due priority to safety and within these, make and implement adequate quality management arrangements in respect of all matters which may affect safety.
I carried out a planned one day, on-site LC 17 compliance inspection within the Decommissioning Directorate. The inspection comprised discussions with SL staff and reviews of Directorate and Programme records and other documentation. I was accompanied on this inspection by ONR's Sellafield Corporate Inspector (who is a specialist in leadership and management for safety), and by the Environment Agency's Inspector for Decommissioning. As part of my preparation for the delivery of this intervention, I consulted the following formal ONR guidance:
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 Management Systems in place in the Decommissioning Directorate. I was satisfied that the Management System is an integrated part of the wider Sellafield site management system which, as implemented in Decommissioning Directorate, meets the requirements of LC 17 and gives due priority to safety. In my opinion, the licensee has implemented their arrangements for compliance adequately.
I also sampled the governance arrangements supporting the implementation of the Management System. In my opinion there were a number of instances of good practice, such as the improvement programme in place in Decommissioning. However this is balanced by observations I made regarding the current complexity of these arrangements which unless addressed may lead to a sub-optimal management system.
From those areas sampled, I did not identify any significant shortfalls in the licensee's formal arrangements for compliance, other than those already acknowledged and being tracked through ONR's Regulatory Issues database.
I consider that the licensee has complied with its arrangements, and that although there are minor shortfalls identified, I am confident that these will be rectified within appropriate timescales. It is my opinion that, against compliance with Licence Condition 17, an inspection rating of Green (no formal action) is merited.
From the evidence sampled during this inspection, I judge that there was sufficient evidence that the licensee's formal arrangements for compliance with Licence Condition 17 are being implemented adequately in the Decommissioning Directorate.