Office for Nuclear Regulation

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HALES unannounced LC26 compliance inspection and planned LC28 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 June 2018. 

Interventions Carried Out by ONR

On 5 June 2018, I, the site inspector for the operational waste facilities, carried out two  planned licence condition compliance inspections of the Highly Active Liquor Evaporation and Storage (HALES) Plant.  The purpose of this inspection was for the ONR to determine the adequacy of implementation of the licensee’s formal arrangements for compliance with LC26 (control and supervision of operations) for conducting operator rounds, and LC28 (examination, inspection, maintenance and testing) for non-delivery of scheduled maintenance.  The LC26 compliance inspection was an unannounced inspection.  These inspections comprised of discussions with SL staff, a plant visit and reviews of plant records and other documentation.

I also conducted follow up enquires on a recent event which occurred in High Level Waste Plants (HLWP) and reported under INF1 2018/369.   I also attended the routine quarterly review meetings for the remediation, HLWP and HALES operational units as well as attending the 6 monthly Highly Active Liquor (HAL) strategic forum.

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 LC26 inspection, I undertook a review of the relevant Sellafield procedure against the ONR guidance document for LC26, NS-INSP-GD-026 Revision 3.  From the areas sampled, I did not identify any significant shortfalls in the licensee’s formal arrangements for compliance with LC26 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 arrived unannounced and visited the plant where I asked the Duly Authorised Person (DAP) and on duty operators to explain what operator rounds were undertaken and how this was achieved.  The DAP and on duty operators were able to clearly articulate what rounds were required to be undertaken and the expectations in completing these as detailed in the SL procedures. 

I then sampled a number of operators rounds by accompanying the operators during the completion of these rounds.  I was satisfied that the operators were familiar with the location of each of the instruments to be read, that sufficient time was allowed for completion of these rounds and the appropriate information was being recorded.  I did however note that one of the internal sump level indication instruments had been moved from the B212 plant room 6 to plant room 5 but the round sheet had not yet been updated.  SL agreed to action this amendment.  

I judged that appropriate oversight was being undertaken to ensure that the recorded parameters are within the required range but advised SL to consider compiling a master list of these rounds to ensure they are all completed and returned. 

Notwithstanding these minor observations, on the basis of evidence sampled at the time of this inspection, I judged that the licensee has adequately implemented its arrangements for compliance with Licence Condition 26 (control and supervision of operations) with respect to operator rounds.  I therefore consider that the required standard was met and an inspection rating of Green (No Formal Action) is merited.

Prior to the LC28 inspection, I undertook a review of the relevant Sellafield procedure against the ONR guidance document for LC28, NS-INSP-GD-028 Revision 5.  From the areas sampled, I did not identify any significant shortfalls in the licensee’s formal arrangements for compliance with LC28 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 asked SL to explain how the facility manages non-delivery of scheduled maintenance.  The maintenance manager and his deputy were able to clearly articulate the process documented within the SL procedures.

Prior to this inspection I was provided with the current numbers of non-delivered maintenance and sampled the justifications for non-delivery of a key number of items on this list.  SL was able to explain why these items had not been delivered and provided appropriate justification to demonstrate the continued safe operation of the plant.

I judged that the licensee has adequately implemented its arrangements for non-delivery of scheduled maintenance under Licence Condition 28 (examination, inspection, maintenance and testing).  I therefore consider that the required standard was met and an inspection rating of Green (No Formal Action) is merited.

As a result of my follow up enquiries on the event reported under INF1 2018/369 I am satisfied that SL are taking the appropriate actions to address any learning and that the event does not meet the ONR formal investigation criteria.

The remediation, HLWP and HALES quarterly review meetings are routine meetings where SL gives an update on the operational activities of the plants within those facilities to the Environment Agency and ONR.  No areas of significant concern were identified.

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.