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, Decommissioning, Fuel and Waste (SDFW) Division. The planned inspection schedule for the current regulatory year (covering April 2017 - March 2018), the content of which is guided by that strategy, identifies the Licence Conditions (LCs) that will be inspected over this period.
This planned inspection was undertaken to determine if SL's Water Treatment Plant is adequately implementing the licensee's site-wide arrangements for compliance with Licence Condition 10 (training) and Licence Condition 28 (examination, inspection, maintenance and testing). The reliable provision of demineralised water to the Sellafield site is important to ensure the safe operation of facilities important to nuclear safety, as well as facilitating hazard and risk reduction activities on the site (e.g. providing water for steam, pond purges).
The overall adequacy of SL's site-wide LC 10 and 28 arrangements is considered separately in other ONR inspections.
Licence Condition 10 (LC 10) requires the licensee to make and implement adequate arrangements for suitable training for all those on site who have responsibility for any operations which may affect safety.
My inspection, which comprised discussions with SL staff, examination of plant documentation, and inspection of facilities and equipment, focussed on SL's:
Licence Condition 28 (LC 28) requires the licensee to make and implement adequate arrangements for the regular and systematic examination, inspection, maintenance and testing of all plant which may affect safety.
My inspection, which comprised discussions with SL staff, examination of plant documentation, and inspection of its facilities, focussed on SL's:
Not applicable; this was not a safety system based inspection.
There were no significant findings identified during my inspection of the licensee's implementation of arrangements for LC 10 within the Water Treatment Plant. I noted that the licensee had recognised that there was a shortfall in the provision of a DAP and had put in steps to rectify the situation and DAPs already appointed within the Inactive Tank Farm (ITF) were going through a training programme. Similarly the training programme for new starters has been updated to reflect modern practices and is being implemented.
For these reasons, and on balance, I consider an inspection rating of Green (no formal action) is merited against LC 10 as a result of this inspection.
From my inspection findings, focussed on the provision of the site wide demineralised water supply, I consider the implementation of the licensee's arrangements for LC 28 within the Water Treatment Plant is good in some areas. For instance, there was good evidence in relation to general situational awareness regarding the status of the system from an ongoing operational perspective, and also the need for improvements to asset care going forwards. This is, however, offset by a number of shortfalls, in particular, the Plant Maintenance Schedule did not reflect the present safety case and all necessary items important to safety for the demineralised water supply system.
For these reasons, and on balance, I consider an Inspection rating of Amber (Seek Improvement) is merited against LC 28 as a result of this inspection.
My findings were shared with and accepted by the licensee as part of normal inspection feedback. I have determined based on the evidence provided, that the present safety case does not adequately identify the structures, systems and components important to safety and this is reflected within the licensee Plant Maintenance Schedule. The licensee is in the process of implementing a new safety case, however based on my findings it does not meet ONR regulatory expectations in regards to the methodology undertaken to produce the document. Therefore I have raised a Level 3 regulatory issue.
I have also determined that the licensee is undertaking a configuration review of the plant, which will aid the identification of single point vulnerabilities and an appropriate maintenance strategy. However this programme of work has only just started, therefore I have raised an action within the Level 3 regulatory issue to monitor progress.
Similarly I have identified that the new operator training package for the facility does not include an adequate consideration of the consequences of failure to supply demineralised water to either the correct quality or volume. Therefore I have raised an action within the Level 3 regulatory issue for the licensee to consider amending the training package to address consequences adequately.