This was a planned Licence Condition compliance inspection, supporting ONR’s five-year rolling programme across the licence conditions to ensure Sellafield Ltd (SL) is managing the Sellafield site safely.
This intervention was performed to determine if the Waste Vitrification Plant (WVP) area is adequately implementing SL’s site-wide arrangements for compliance with Licence Condition 22.
Licence Condition 22 requires the licensee to make and implement adequate arrangements to control modifications to its plants or processes that may affect safety. The licence condition also imposes other duties, e.g. on experiments, on the classification of modifications and on hold-points.
My inspection examined several areas:
Not applicable, this was not a Safety System inspection.
Within WVP, the prominent improvement identified was SL’s introduction of action plans for new PMPs, such that PMPs are actively managed to avoid them threatening the licensee’s three and one year age limits for permanent and temporary PMPs respectively.
I am content that staff within WVP are on a path to reducing the number of open PMPs exceeding (or threatening to exceed) the licensee’s limits. This is being managed through SL’s introduction of weekly PMP progress reviews and a tracking spreadsheet controlled by the Engineering Manager.
I found no issues with the closed PMPs I sampled. I noted that the categorisation of the PMPs appeared appropriate and good use was made of the PMP progress review forms in explaining reasons for delays in closure.
Outside of the sphere of WVP’s direct responsibility, I confirmed that the ambiguity introduced by SL’s site-wide arrangements for “Safety Case Only” modifications is a real effect. For example, changes have been made to the WVP safety case (that have a potential nuclear safety impact), without raising PMPs and utilising only Safety Case Implementation Plans. However, I am content that, as the PMP committee remains involved, nuclear safety has been maintained throughout.