Attendance at Remediation Quarterly Review Meeting, Attendance at the Highly Active Liquor Strategic Forum, Follow up on a Recent Event in the Highly Active Liquor Evaporation and Storage (HALES) Plant and Compliance inspections of Licence Conditions 26 (Control and Supervision) and 28 (examination, inspection, maintenance and testing) within HALES.
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 Sub Division. In accordance with that strategy, Licence Condition (LC) compliance inspections were carried out on the Operational Waste Facilities Operating Unit (OU), as planned, in October 2017.
On 7 December 2017, I, the site inspector for the operational waste facilities, accompanied by the ONR Sellafield corporate inspector, carried out two planned licence condition compliance inspections of the Highly Level Waste Plants (HLWP). The purpose of this inspection was for the ONR to determine the adequacy of implementation of the licensee's formal arrangements for compliance with LC 26 (control and supervision) and LC28 (examination, inspection, maintenance and testing). The inspection comprised of discussions with SL staff, interviews with operational staff, and reviews of plant records and other documentation.
In addition I also attended the remediation quarterly review meeting, the strategic highly active forum and conducted follow up enquiries in the Highly Active Liquor Evaporation and Storage (HALES) facility following a recently reported event in this facility (INF1 2017/770).
This was not a system based inspection, and therefore no judgement has been made of the adequacy of implementation of any part of the safety case.
Prior to the LC26 and LC28 inspection, I undertook a review of the relevant Sellafield procedures against the relevant ONR guidance document for these licence conditions; NS-INSP-GD-026 Revision 3 and NS-INSP-GD-028 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 the LC26 arrangements within the facility, I sampled the training records and letters of appointment for a number of individuals undertaking control and supervision activities. For LC28 I sampled a number of maintenance records for the confluence pot pressure and various sump ejector level instruments.
I was satisfied that the facility had followed the company procedures for LC26 and had produced an adequate baseline for control and supervision. Whilst the difference between a Duly Authorised Person (DAP) and an Appointed Suitably Qualified and Experience Person (ASQEP) was understood, 3 individuals (Non DAPs) had not been formally appointed to their control and supervision roles and therefore a level 4 issue was raised to rectify this.
For LC28 I selected the sample from those plant items which had recently had their maintenance periodicity extended from 12 months to 24 months. Whilst the maintenance had been completed, I gave some advice on how this could be improved by recording greater plant condition data. I explained that the suggested improvements would support the 2 year review of the effectiveness of the maintenance periodicity extension requested by the Management Safety Committee. In order to monitor this work I have raised a level 4 issue for the outcome of the review to be sent to ONR when completed.
Notwithstanding the above, from the areas sampled I was satisfied that the facility had adequately implemented the site arrangements for LC26 and LC28. On this basis I judged that compliance with LC26 and LC28 followed the relevant company procedures and met the required standard and therefore I have rated this intervention against these licence conditions as Green.
As part of my follow up enquiries I discussed INF1 2017/770, which relates to the failure of a number of vacuum relief valves, with the HALES operational support manager. I also reviewed the associated paperwork and whilst I judged that this event does not meet the ONR formal investigation criteria, I have raised some question on the extent of use of these particular relief valves. I will pursue the response to these questions as part of normal regulatory 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 Operational Waste Facilities Operating Unit at the Sellafield Nuclear Site as set out in the Integrated Intervention Strategy, which will continue as planned.