The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Sellafield site licensee (Sellafield Ltd, SL) against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. In accordance with this strategy, a Licence Condition (LC) 24 (Operating Instructions) arrangements inspection was carried out, as planned, on 21-22 June 2017. The purpose of the inspection was to determine whether SL’s arrangements are adequate to ensure the site’s compliance with LC24. The inspection drew intelligence from other ONR inspections which examine the implementation of the site-wide arrangements in operating facilities.
A team comprising the ONR Corporate Inspector and Human Factors Lead Inspector carried out the inspection. The inspection focussed on SL’s arrangements for compliance with LC24, SL’s response to the open regulatory issue 3895 (concerning inconsistency in the quality of, and adherence to, operating instructions) and intelligence from events, inspections and assessments (by ONR and SL) on LC24 compliance.
The inspection comprised a review of relevant management system processes and records, a review of event trend and assurance reports, and discussion with SL’s process owner for disciplined operations and human performance (including LC24), and members of the disciplined operations team. ONR’s technical inspection guide NS-INSP-GD-024 (LC24 Operating Instructions) and technical assessment guide NS-TAST-GD-060 (Procedure Design and Administrative Controls) formed the basis for the inspection.
Not applicable as this was not a system based inspection.
I found the SL staff who took part in the inspection to be experienced and knowledgeable in the requirements of LC24 and the key challenges facing the site. They were able to evidence the support they give to operating facilities on implementation of SL’s LC24 arrangements, and the improvements which have resulted.
I found SL’s written arrangements for compliance with LC24 to contain the core elements of relevant good practice, with some minor gaps. However, I found significant shortfalls in other aspects of SL’s arrangements, as summarised below:
There is evidence of inconsistent implementation of SL’s LC24 arrangements by operating facilities, including shortfalls in the documentation of risk assessments and over-categorisation of operating instructions as ‘continuous use’. Furthermore a safety climate survey carried out by SL in 2015 identified weaknesses in procedures as a key theme. During this inspection ONR did not identify any significant, adverse trends in events on the site as regards procedure quality and adherence, however it has emerged as a theme from recent event investigations.
During the course of the inspection, SL presented its improvement plan to address regulatory issue 3895. I found this to address some of the shortfalls identified above, but it contains no information on required resources or timescales, and there is insufficient detail on assurance activities which would test the effectiveness of the plan in practice. It also lacks senior management endorsement. SL agreed to address these shortfalls and present a revised improvement plan to ONR by 31 July 2017.
As noted above, my inspection revealed broader shortfalls in SL’s arrangements for implementation of its disciplined operations standards. SL advised that it used to have in place a disciplined operations strategy review group, a practitioner’s group and coaches in each operating unit, however this hasn’t been operational since approximately 2013 and it was not clear to me what has replaced it. It also appears that there is a mismatch in the accountability and authority of the Head of Profession (Operations) in respect of disciplined operations. I therefore propose to raise a new regulatory issue at Level 3 for SL to explain its delivery model for disciplined operations and demonstrate adequate capability to support it. I consider this appropriate because of SL’s continuing reliance on procedural controls in hazard and risk reduction.
I consider there to be a significant shortfall in the licensee’s arrangements for compliance with LC24. These are identified in an existing regulatory issue (3895) which I propose to maintain at ‘Amber’ (unsatisfactory performance), subject to SL presenting an adequate improvement plan to ONR by 31 July 2017. It is my opinion that an inspection rating of ‘Amber’ (seek improvement) is merited.