This intervention was to inspect the arrangements for compliance to Licence Condition 7 (notification of incidents on the site) within Sellafield Ltd (SL's) Decommissioning Division.
Inspection of Licence Condition (LC) compliance at nuclear licensed sites is an important part of ONR's activities. ONR's Sellafield Programme has defined a programme of system inspections and LC compliance inspections that focuses on those parts of the site and activities where the risk or hazards are most significant. This inspection forms part of that programme and is identified on the Sellafield PP3 Inspection plan, which covers the Decommissioning Division.
I carried out an inspection of the arrangements for reporting incidents in the Sellafield Decommissioning Division through a series of interviews and reviews of documents and records. This inspection was carried out in accordance with ONR's inspection guidance for Licence Condition 7 (LC7) for Incidents on the Site as defined in NS-INSP-GD-007.
N/A - This was not a Safety Systems inspection.
I was satisfied that Sellafield Decommissioning Division has established and implemented Arrangements which meet the requirements of Licence Condition 7, for reporting and investigating incidents on the site. Licensees have a duty to report incidents on the site which meet the criteria defined in ONR Guidance ONR-OPEX-GD-001 (Notifying and Reporting Incidents and Events to ONR). The national system for formally recording incidents reported to ONR is using an INF1 form. It was encouraging to note that the INF1 reporting rate across the Decommissioning Division has increased in 2014 in response to the agreed changes to the reporting criteria agreed with ONR in December 2013 (N.b. this does not reflect any increase in incidents, just improvements in reporting - see below).
A number of improvements have been implemented, which demonstrated that the Sellafield Operating Experience and Corrective Action Programme (OPEX/CAP) is progressively being implemented within the Decommissioning Division. This included the recruitment of additional Performance Improvement Advisors, a Trend Manager and an Operating Experience Manager, and implementation of revised local arrangements for sentencing and trend reporting.
Performance Improvement Advisors support plant personnel in daily event sentencing activities to ensure consistency of categorisation. Weekly peer reviews are also carried out to verify event categories (e.g. in light of further information) and to review the status of outstanding investigations and actions. I reviewed the status of outstanding investigations and actions across Decommissioning and these were found to be at reasonable levels at the time of my inspection.
SL has applied significant effort recently to the development of Trend Reports to analyse trends in reported conditions, common causes or areas for further analysis, however this area is still developing and the benefits are not yet evident. The first of the new Trend Reports have been issued but the data in the reports is not yet mature and the conclusions not yet clear. Moreover the previous measures for the OPEX process performance (such as total number of Events raised, Outstanding Investigations, Overdue Actions) are no longer widely available and do not feature in management reviews. The Trend Report is now presented at the Decommissioning Corrective Action Review Board, but it was noted that few senior managers attend this meeting. I commented this appeared to be a backwards step in terms of governance of the process and business performance for OPEX as it was no longer clear how senior management in Decommissioning Division are now suitably engaged.
SL confirmed that the apparent increase in the failure rate of safety mechanisms was not a real effect, and that overall failure rates across site have not increased. The increase in reported failures in the INF1 reporting figures is solely a result of changed reporting criteria agreed between ONR and SL. In support of this, I have not detected any significant increase in the number of Safety Mechanisms within the Initial Event Reporting (IER) lists submitted to ONR on a weekly basis.
The OPEX processes and trend reporting do not include maintenance findings, which are stored separately in the Computerised Maintenance Management System rather than the ATLAS event reporting system. Whilst both systems can be interrogated by the QLikView tool, the maintenance data is not included in the Performance Improvement programme. The reasons for this separation were not clear, but it suggests that further scope for improvements exists by applying the Performance Improvement process and management review to the combined data.
Overall, I judged compliance with Licence Condition 7 to be adequate, as adequate arrangements were demonstrated for the notification, recording, investigation and reporting of incidents on the site. SL recognises there is scope to improve the Trend Reporting and Management Review aspects of its arrangements, and has committed plans in place to address this, so no specific actions were placed as a result of this inspection. The development of these arrangements will be followed up as part of routine regulatory business.