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 Condition 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 14 and 16 February 2017 to examine the adequacy of the site’s arrangements for Licence Condition 35 (Decommissioning). An associated objective of this inspection was to form a view about the effectiveness of the arrangements in supporting effective delivery of decommissioning.
A team comprising a specialist inspector in operational inspection, two specialists in nuclear liabilities regulation, and a specialist in leadership and management for safety undertook the inspection. The inspection comprised discussion of the site-wide arrangements with the LC35 process owner and members of the SL Remediation operating unit, followed by plant walkdowns and desktop reviews of how the arrangements are interpreted and implemented in two parts of decommissioning work at Sellafield:
Not applicable as this was not a Safety System inspection.
From the evidence examined, I consider that SL’s arrangements for compliance with LC35 are generally well-aligned with ONR’s regulatory expectations as summarised in our guidance. However SL was unable to present a clearly documented decommissioning strategy or demonstrate adequate arrangements for the production of the decommissioning strategy. Given the importance of this in relation to SL’s current and future POCO and decommissioning programmes, it is my opinion that these are significant shortfalls.
Other areas for improvement include the need for review of arrangements to integrate, control and oversee the interdependencies between plants and supporting site infrastructure in planning and underpinning POCO and decommissioning. I recommend SL should integrate opportunities and improvements identified at a plant level to the site level more effectively. SL also needs to develop its knowledge management to support POCO and decommissioning activities.
Nevertheless, from the evidence examined, I consider that SL has made good progress since the LC35 compliance inspection undertaken in Legacy Ponds in March 2016. In particular I was content that SL had addressed the previous ONR findings from this inspection, including the issue of a procedure for the production of decommissioning plans and the integration of decommissioning in design documentation for new plant and equipment.
I am also content that SL ensures oversight of its implementation and internal regulatory reviews in this area, and has shown a number of good practices regarding POCO integration, learning from experience, and culture of challenge, to support acceleration and optimisation of decommissioning delivery.
Overall, it is my opinion that SL has broadly adequate arrangements for decommissioning at plant level. However, at a site level, I judge the decommissioning strategy to be not clearly documented, with a lack of clarity in the supporting arrangements. In addition, given that current plans indicate that POCO will be taking place simultaneously in a significant number of facilities, I judge the management of interdependencies should be an additional focus of work that SL should address with the aim of demonstrating its arrangements will support effective delivery of decommissioning. I consider these are significant shortfalls, and so I consider an inspection rating of Amber (seek improvement) to be appropriate.
My findings were shared with, and accepted by the licensee at a feedback session at the close of the inspection. I noted that the licensee was willing to address the areas of improvements identified. I have raised a Regulatory Issue to ensure the shortfalls are clearly identified, and managed to completion by the licensee under regulatory oversight.