The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Sellafield site licensee (Sellafield Limited (SL)) against a strategy defined by the ONR Sellafield Programme. In accordance with that Strategy, a Licence Condition compliance inspection of the HALES facility was carried out as planned in July 2015. Its purpose was to enable the ONR to determine the adequacy of implementation of the licensee’s arrangements for compliance with Licence Conditions 22 and 26, previously identified within the planned inspection schedule for the Waste Effluent Disposition Directorate (WEDD).The HALES facility was chosen for due to the potential for an event on the plant to result in contamination off site.
LC22 requires SL to make and implement adequate arrangements to control any modification or experiment carried out on any part of their existing plant and/or process that may affect safety. Following findings on other facilities, I was particularly interested in the management of temporary modifications to plant or process and the use of safety case implementation plans (SCIPs).
LC26 requires SL to ensure that all operations that affect safety are carried out under the control and supervision of suitably qualified and experienced persons appointed for that purpose.
I carried out a one-day, on-site, licence condition compliance inspection of the HALES facility, with technical support from a Human Factors (HF) specialist, and the Project inspector with responsibility for management of formal permissioning within the ONR SL Programme.
The inspection comprised discussions with SL staff, a plant walk down, and examination of a sample of plant operational records. The inspections were carried out in accordance with the following formal ONR inspection guidance.
N/A. This was not a Systems Based Inspection (SBI).
Based on a sample of the plant documentation associated with the control of the temporary modification of plant systems, I consider that the management of the SCIP process, which enacts more limited controls than the Plant Modification Process (PMP), is effective, but that recent clarification regarding the constraints on its use had not been communicated effectively by the licensee to the HALES facility.
Within the inspection, I identified that the other arrangements in place for the control of temporary plant modifications were being implemented effectively. Furthermore, it was my view that sustained effort was being applied by the facility to minimise the volume of longstanding, active plant modification documentation, which will reduce the risk from a loss of plant configuration in the future.
From the sample observed whilst on plant during the inspection it was my opinion that the supervision and control of operations was effective and adequate. Additionally, there was evidence of a proactive approach being taken by the HALES management team to identifying areas for continuing improvement, utilising the site-wide process for operational oversight by management personnel from both within and out-with the facility.
From the evidence sampled during this inspection, I judge that the licensee has implemented adequately their arrangements for compliance with Licence Condition 22, and thus consider that an IIS rating of 3 (Adequate) is merited.
From the evidence sampled during this inspection, I judge that the licensee has implemented adequately their arrangement for compliance with Licence Condition 26, and in a number of cases is delivering sustained focus on delivering effective supervision on plant, and thus consider that an IIS rating of 2 (Good) is merited.