The Office for Nuclear Regulation (ONR) undertakes all regulatory interactions with Sellafield Limited (SL, the site licensee) against a strategy defined by the ONR Sellafield Programme. My planned inspection schedule, PP5, for the current regulatory year (covering April 2015 – March 2016), the content of which is guided by that strategy, identifies the Licence Conditions (LCs) that will be inspected over this period.
I undertook the planned LC 28 inspection by meeting with facility representatives in both areas of the Effluent & Encapsulation Plants (E&EP) Operating Unit; Low Active Effluent Management Group (LAEMG) and Encapsulation Plants. This OU was selected for inspection since it consists of a number of ageing facilities with a wide range of nuclear safety challenges and the possibility of the extension of operating life to provide waste management services or other areas of the site. This requires E&EP to maintain the equipment on which it relies to deliver adequate nuclear safety performance, whilst supporting high hazard reduction on the Sellafield licenced site.
The purpose of Licence Condition 28 (LC28) is to ensure that SL make and implement adequate arrangements for the regular and systematic Examination, Inspection, Maintenance and Testing (EIM&T) of all plant that may affect safety.
My inspection, which comprised discussions with SL staff and examination of the Plant Maintenance System (PMS), documentation and training records focussed on the following areas:
Not applicable; this was not a Safety System inspection.
I consider that SL’s arrangements for compliance with LC 28 have been effectively implemented within the E&EP OU. I did, however, identify some minor improvements that could be made, all of which were accepted by the licensee.
I consider the facility’s implementation of the site’s arrangements for LC28 is adequate. Additionally, there are areas where the licensee is seeking improvement; event trending and effective use of investigation. For these reasons, on balance, I consider the inspection findings merit an IIS rating of 3 (adequate) against LC28. This is consistent with the IIS ratings guidance, for which the relevant extract is:
“…Arrangements meet guidance requirements. Some opportunities for improvement under ALARP. Areas for improvement known, but being addressed only slowly. Site inspector able to identify minor points for improvement.”