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 Highly Active Liquor Evaporation and Storage (HALES) Operating Unit (OU) was carried out as identified within the planned inspection schedule for the Waste Effluent Disposition Directorate (WEDD).
This planned intervention was undertaken to determine if the HALES OU is adequately implementing SL's site-wide arrangements for compliance with Licence Conditions 10 (training), 11 (emergency arrangements), 12 (duly authorised and other suitably qualified and experienced persons) and 36 (organisational capability). The HALES OU was chosen because of the radiological hazard associated with its inventory.
I carried out a two-day, on-site, licence condition compliance inspection of the HALES OU, assisted by two ONR nuclear safety inspectors. Subsequent to the compliance inspection I held a number of routine intelligence gathering meetings.
The inspection comprised discussions with Sellafield Ltd staff, a partial plant walk down, and examination of a sample of plant operational and administrative records. The inspections were carried out in accordance with the following formal ONR inspection and assessment guidance:
N/A; this was not a Systems Based Inspection (SBI).
I observed that SL utilise training gap analysis spreadsheets in its transition to fully embed a systematic approach to training within its arrangements. I consider the use of these spreadsheets to be good practice and I advised SL to formally introduce them into its management processes. Overall, from the evidence sampled during this inspection, I consider that SL has effectively implemented its arrangements for compliance with both Licence Condition 10 and Licence Condition 12, and I have assigned an inspection rating of Green (No Formal Action) in respect of both these Licence Conditions.
SL accepted my observation that the management of information relating to training and competence of staff for emergency arrangements could be done in a more efficient manner. For example, records of attendance for individuals that have participated in emergency exercise drills are not formally recorded, when this is a valid component to the demonstration of overall competence. I have generated a minor Regulatory Issue on this matter and I will follow this up during future routine regulatory engagements. Overall, however, from the evidence sampled during this inspection, I consider that SL has effectively implemented its arrangements for compliance with Licence Condition 11, and I have assigned an inspection rating of Green (No Formal Action) here.
From the evidence sampled during this inspection, I consider that SL has effectively implemented its arrangements for compliance with Licence Condition 36, and I have assigned an inspection rating of Green (No Formal Action) here.
My findings were shared with, and accepted by SL, as part of routine inspection feedback. I have raised one minor Regulatory Issue as a result of this inspection. This Regulatory Issue places an expectation on SL to improve the administrative records associated with its emergency arrangements.