Office for Nuclear Regulation

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Effluent & Encapsulation Plants Quarterly Review Meeting No. 40  Highly Active Liquor Evaporation and Storage (HALES) - LC22 and LC28 Compliance Inspections

Executive summary

Purpose of Intervention

The purpose of this intervention was to carry out licence compliance inspections at the Highly Active Liquor Evaporation and Storage (HALES) plant on the Sellafield Ltd site in line with the planned inspection programme contained in the Operational Waste Facility (OWF-PP5) Integrated Intervention Strategy (IIS) for 2017/18. 

Interventions Carried Out by ONR

I, the OWF site inspector carried out planned Licence Condition (LC) compliance inspections against LC22 – modification or experiment on existing plant and LC28 -  examination, inspection, maintenance and testing within HALES.  I also attended the Effluent and Encapsulation Plants (E&EP) quarterly review meeting. 

Explanation of Judgement if Safety System Not Judged to be Adequate

No safety system inspection was undertaken, hence this is not applicable.

Key Findings, Inspector's Opinions and Reasons for Judgements Made

 Prior to this inspection, I carried out a review of the company LC22 procedures against the relevant ONR guidance documents for these licence conditions.  I judged that these procedures provide adequate arrangements to satisfy the requirements of LC22.

In order to judge the adequacy of the implementation of the LC22 arrangements, I sampled a number of requirements within the corporate documentation as well as a number of recent Plant Modification Proposals (PMPs).

From the areas sampled I judged that the overdue PMPs were being adequately managed however I noted that the required annual review on each overdue PMP has not yet been undertaken.  Consequently a level 4 regulatory issue has been raised to ensure this is completed promptly.

I reviewed and confirmed that the PMP committee chairman and PMP project managers had undertaken the required corporate training.

I also sampled and confirmed that recent PMPs had undergone the appropriate due process.

Notwithstanding the minor issue raised above, on the basis of the areas sampled I judged that compliance with LC22 followed the relevant company procedures and met the required standard.  I therefore have rated this intervention against LC22 as Green.

The main purpose of the LC28 compliance inspection was to follow up progress on improvements made to the maintenance capability within HALES and reduction in maintenance backlog.  These concerns were raised during previous LC28 compliance inspections and resulted in ONR regulatory issue 3428 being raised.

I undertook a review of the relevant company LC28 procedures during this inspection and judged that these procedures provide adequate arrangements to satisfy the requirements of LC28. In order to judge the adequacy of the implementation of these arrangements, I targeted the improvements to the maintenance capability and management of the maintenance backlog in accordance with the company procedures.

Following discussions with the maintenance manager and a review of the improvements that have been made I judge that sufficient progress has been made to address the final action of ONR regulatory issue 3428, which will be recorded as complete.

I sampled a number of recent justifications for non-delivery of scheduled maintenance and judged that these had been completed in accordance with the relevant corporate procedure. 

On the basis of the areas sampled I judged that compliance with LC28 followed the relevant company procedures and met the required standard.  I therefore have rated this intervention against LC28 as Green.

I also took the opportunity to discuss a recent event relating to calibration drift of a level indicator.  As a result of these discussions an ONR level 4 regulatory issue was raised for Sellafield to review the performance of the level indicator to confirm it meets the safety case requirements.

The E&EP quarterly review meeting followed a standard agenda which included an update of the current performance in each of the areas within the E&EP portfolio.  In particular Sellafield presented the work they had undertaken to review proof testing to address one of the actions raised in ONR regulatory issue 5248.  I judged that the work undertaken addressed actions 1 and 2 of issue 5248.

The intervention was performed in line with ONR’s guidance requirements (as described in our technical inspection guides) in the areas inspected.

Conclusion of Intervention

From the evidence gathered during this intervention, I do not consider there to be any matters that have the potential to impact significantly on nuclear safety.    

At present, no additional regulatory action is needed over and above the planned interventions within the Highly Active Liquor Evaporation and Storage facility or Effluent and Encapsulation plants at the Sellafield Nuclear Site as set out in the Integrated Intervention Strategy, which will continue as planned.