HLWP - LC 11 Compliance Inspection, Attendance at the Remediation, HLWP and HALES Quarterly Review Meetings and Follow Up on ONR Issue 5265 and INF1 2017/588
The purpose of this intervention was to carry out a licence compliance inspection at the High Level Waste Plants (HLWP) 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.
I, the ONR Operational Waste Facilities site inspector undertook an LC11 - Emergency Arrangements compliance inspection of the HLWP. I also attended the Remediation, HLWP and Highly Active Liquor Evaporation and Storage (HALES) quarterly review meetings. In addition I conducted follow up enquiries following an event in the Engineering Drum Stores (EDS) and reviewed progress with ONR issue 5265.
No safety system inspection was undertaken, hence this is not applicable.
Prior to the LC11 inspection, I undertook a review of these procedures against the relevant ONR guidance document for this licence condition, NS-INSP-GD-011 Revision 5. From those areas sampled, I did not identify any significant shortfalls in the licensee's formal arrangements for compliance which would prompt an inspection of those arrangements earlier than currently planned.
In order to judge the adequacy of the implementation of these arrangements within the facility, I targeted how the emergency response scenarios are derived and the justification and rationale for the practical training given to the emergency scheme members. The emergency scheme training records are currently subject to ONR regulatory Issue 4849.
Within the HLWPs there are a large number of Emergency Operating Instructions (EOIs) and whilst there is a comprehensive exercise and drill schedule, the facility could not explain the rationale for this schedule in relation to these EOIs and the sustained competency of the emergency scheme members.
I also noted that, although the annual review of the previous years (2016/17) emergency exercises had been completed, it had not been accepted by the MSC and is due to be re-presented at the October meeting. I therefore requested a copy of the annual exercise review and the MSC minutes when approval has been given.
In light of the findings above I superseded the HLWP aspect of ONR issue 4849 with a new regulatory issue (5759) which requires SL to explain and record the rationale for sustaining the competency of the HLWP emergency scheme members with respect to the identified EOIs and the emergency exercise and drills schedule.
Notwithstanding the issue raised above, on the basis of the areas sampled I judged that compliance with LC11 followed the relevant company procedures and met the required standard and therefore I have rated this intervention against LC11 as Green.
I also attended the Remediation, HLWP and HALES routine quarterly review meetings where Sellafield Ltd gave an update on current and future operations in these facilities.
Although SL has made good progress with ONR issue 5265, further work is required to enable me to record this issue as closed.
Following the downgrading of contamination controlled area within the EDS, there was a breach of the local radiological rules. Since this was a reportable event (to ONR), I conducted follow up enquiries. The facility had missed the fact that there are two sets of local rules; one for the route into the area and one for the operators. Since only one set of local rules were amended to reflect the downgrading of the area, this resulted in a breach of the other set of local rules which still reflected the personal protective equipment required for the higher classified area. An internal investigation is ongoing and is due to be completed by the end of the month.
I have reviewed the associated documentation and spoken to the facility managers and I am satisfied that no formal regulatory action is required at this time, however I will follow up this issue on completion of the internal investigation as part of normal business.
The intervention was performed in line with ONR’s guidance requirements (as described in our technical inspection guides) in the areas inspected.
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 High Level Waste Plants and Engineered Drums Stores at the Sellafield Nuclear Site as set out in the Integrated Intervention Strategy, which will continue as planned.