Office for Nuclear Regulation

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Sellafield Ltd - LC11 Compliance inspection

Executive summary

Purpose of Intervention

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 April 2018. 

Interventions Carried Out by ONR

On 11 April 2018, I, the site inspector for the operational waste facilities, accompanied by an ONR project inspector, carried out a planned licence condition compliance inspection of the Highly Active Liquor Evaporation and Storage (HALES) facility.  The purpose of this inspection was for the ONR to determine the adequacy of implementation of the licensee’s formal arrangements for compliance with LC11 (emergency arrangements).  The inspection comprised of discussions with SL staff, a plant visit and a review of emergency response staff training records.

On 12 April 2018, I, accompanied by an ONR project inspector and the ONR nominated site inspector for compliance, inspection and enforcement, carried out planned licence condition compliance inspections of the Engineered Drum Stores (EDS) within the alpha remediation operating unit.  The purpose of this inspection was for the ONR to determine the adequacy of implementation of the licensee’s formal arrangements for compliance with LC12 (duly authorised and other suitably qualified and experienced persons) and LC26 (control and supervision of operations).  The inspection comprised of discussions with SL staff, a plant visit and a review of training records.

In addition I also conducted follow up enquires on some recent events which occurred in HALES and High Level Waste Plants (HLWP) and reported under INF1s 2018/205, 2018/206 and 2018/221.   

Explanation of Judgement if Safety System Not Judged to be Adequate

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.

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

Prior to the LC11 compliance inspection in HALES, I undertook a review of the relevant Sellafield procedures against the ONR guidance document for LC11, NS-INSP-GD-011 Revision 5.  From the areas sampled, I did not identify any significant shortfalls in the licensee’s formal arrangements for compliance with LC11 which would prompt an inspection of these arrangements earlier than currently planned. 

In order to judge the adequacy of the implementation of these arrangements I sampled the training requirements and associated records for the Emergency Duty Team (EDT).  Under the route to competence initiative, SL has introduced new Suitably Qualified and Experience Person (SQEP) role assessment specifications for each member of the EDT from the 1 April 2018.  Unfortunately none of the incident controllers have yet completed all of the required training detailed in their new role.  Further discussions indicated that this shortfall applies to the majority of the other roles within the EDT and is likely to be a site wide issue.  Notwithstanding this, SL believes that the EDT members are SQEP due to their previous training and experience, unfortunately there is no written justification to support this assertion.   Whilst there was no direct evidence to challenge the competence of the EDT, SL has not met their legal requirements as they have not yet fully implemented this aspect of the site arrangements for compliance with LC11.    In light of this I have rated compliance with LC11 as Amber and will be seeking the necessary improvements via a regulatory letter to the company. 

I have also raised two level 4 regulatory issues.  One relating to the inclusion of a rationale to the emergency drills and exercise schedule document, and one relating to improvements to the document and equipment control within the incident control centre and access control point.

Prior to the LC12 and LC26 compliance inspections in EDS, I undertook a review of the relevant Sellafield procedures against the ONR guidance documents for LC12 and LC26, NS-TAST-GD-027 Revision 5 and NS-INSP-GD-026 Revision 3 respectively.  From the areas sampled, I did not identify any significant shortfalls in the licensee’s formal arrangements for compliance with LC12 and 26 which would prompt an inspection of these arrangements earlier than currently planned.

In order to judge the adequacy of the implementation of these arrangements I sampled the role profiles and associated training for a number of Duly Authorised Persons (DAPs).  I was satisfied that the individuals sampled had undertaken the required training and been appropriately appointed in writing.  I have raised a level 4 regulatory issue to improve the quality of an individual waiver in lieu of training.

I also reviewed the adequacy of the LC26 control and supervision baseline document and noted that the document is currently out of date and have therefore raised a level 4 regulatory issue for this to be updated.

SL has drafted new role profiles for Appointed SQEPs under LC26 with an implementation period ending on the 28 September 2018.  Accordingly I have raised a level 4 regulatory issue to monitor this implementation.

I also undertook a plant visit to the EDS and spoke to the on-duty DAP.  He was very knowledgeable about his role and was able to clearly articulate his duties as DAP from both an LC12 and LC26 perspective. 

Notwithstanding the minor shortfalls identified above, I judge that, on the basis of evidence sampled at the time of this inspection, the licensee has adequately implemented its arrangements for compliance with Licence Condition 12 (duly authorised and other suitably qualified and experienced persons) and Licence Condition 26 (control and supervision of operations).  I therefore consider that no formal action is required and an inspection rating of Green (No Formal Action) is merited for both Licence Conditions.

As a result of my follow up enquiries on the events reported under INF1s 2018/205, 2018/206 and 2018/221, I am satisfied that SL are taking the appropriate actions to address any learning and that the events do not meet the ONR formal investigation criteria.  Notwithstanding this, I have raised two level 4 Regulatory Issues to track these actions.

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 Operational Waste Facilities Operating Unit at the Sellafield Nuclear Site as set out in the Integrated Intervention Strategy, which will continue as planned.