- Site: LLWR
- IR number: 19-134
- Date: November 2019
- LC numbers: 14, 15, 17
Executive summary
Purpose of Intervention
This was one of programme of planned inspections at the Low Level Waste Repository during 2019/20, developed in accordance with the Decommissioning Fuel & Waste Sub-Division strategy.
Interventions Carried Out by ONR
I inspected LLWR’s arrangements for compliance with Licence Conditions 14 (Safety documentation), 15 (Periodic review) and 17 (Management systems).
Explanation of Judgement if Safety System Not Judged to be Adequate
Not applicable.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
I examined LLWR’s arrangements for production and assessment of safety cases, and for the periodic and systematic review and reassessment of safety cases. I noted areas of good practice and offered advice regarding minor opportunities for improvement within LLWR’s arrangements.
I examined LLWR’s quality management arrangements as part of my follow up to an enforcement letter, issued to LLWR in December 2018, following a transport non-conformance resulting from failure to control quality during manufacture of the Novapak Type B transport containers. I consider that the immediate enhancements to LLWR’s arrangements specific to the Type B transport package-manufacturing programme have been implemented adequately, but that the wider learning still needs to be applied and embedded within its overarching management system. LLWR has identified a comprehensive improvement programme to enhance its overall quality management capability, including implementing improvements to its arrangements.
Conclusion of Intervention
I concluded that LLWR’s arrangements for compliance with LCs 14 and 15 were adequate, and that LLWR was able to provide demonstration that implementation of those arrangements is adequate.
I concluded that LLWR’s arrangements for compliance with LC17, specifically with respect to quality management arrangements, were not adequate. The shortfalls within LLWR’s arrangements identified during the internal management investigation into the Novapak non-conformance have only partially been addressed. Suitable actions have been identified within LLWR’s Quality Improvement Programme to remedy the remaining shortfalls within adequate timescales. Completion of these actions and implementation of revised arrangements will be monitored through routine regulatory business.