The Office for Nuclear Regulation (ONR) undertakes all regulatory interactions with Sellafield Limited (SL, the site licensee) in line with a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste Programme. As part of this Strategy, ONR carries out Licence Compliance Arrangements Inspections. These examine whether SL's site-wide arrangements are adequate to ensure the site's compliance with the conditions of its nuclear site licence.
This planned intervention was undertaken between 11-13 October 2016 to examine the adequacy of the site's arrangements for Commissioning (Licence Condition 21). In addition, a particular focus of this inspection was to evaluate the adequacy of the arrangements to support SL's delivery of high hazard and risk reduction at the site.
The inspection comprised discussion of the site-wide arrangements with the LC21 process owner and members of the SL commissioning 'capability' team, followed by a desktop review of how the arrangements are interpreted and implemented by three parts of Sellafield:
In arriving at my conclusions concerning adequacy of the arrangements I also considered the recent experience of ONR colleagues engaged in the regulation of commissioning at SL.
Not applicable as this was not a Safety System inspection.
From the evidence examined, I consider that SL's arrangements for compliance with LC21 are generally well-aligned with ONR's regulatory expectations as summarised in our guidance. However some specific weaknesses were identified in relation to a lack of systematic verification and validation of operational and human factors requirements deriving from SL's design and safety cases processes. Given the importance of operational controls in relation to SL's current and future high hazard and risk reduction projects, it is my opinion that this is a significant shortfall.
Nevertheless, from the evidence examined, I consider that SL has made good progress in addressing historic problems with the efficiency and effectiveness of its commissioning processes, notably in relation to ensuring a 'fit-for-purpose' approach to hazard and risk reduction activities. The improvements include a clearly-described graded approach that encourages flexibility and proportionality and discourages wasteful practices such as repetitive testing and testing that is not risk-based. We noted however, that careful oversight will be needed to ensure that the flexibilities allowed in the approach do not result in inadequate commissioning being undertaken. We also suggested that further work is needed to ensure that the graded approach is applied better in smaller projects.
Other improvements noted include earlier integration of 'pre-operational' stages of commissioning in major projects and effective arrangements for SL's commissioning engineers to share learning and promote consistency.
Overall, it is my opinion that SL's improved arrangements will make an important contribution to support the licensee's work to deliver accelerated high hazard and risk reduction work at the site. However, given the significant shortfall with regard to verification and validation of operational and human factors requirements, I have awarded an inspection rating of Amber (seek improvement).
My findings were shared with, and accepted by the licensee at a feedback session at the close of the inspection. I note that the licensee already has work programmes in place to address several aspects of the weaknesses identified. These and other remedial activities will be tracked through an ONR regulatory issue so that the shortfalls identified are addressed in a timely manner.