Office for Nuclear Regulation

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LC22 and LC28 compliance inspections and quarterly review meeting

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 September 2018. 

Interventions Carried Out by ONR

On 12 September 2018, I, the site inspector for the operational waste facilities, accompanied by an ONR human factors specialist inspector and nuclear graduate, carried out two planned licence condition compliance inspections of the High Level Waste Plants (HLWP), Waste Vitrification Plant (WVP).  The purpose of these inspections was for the ONR to determine the adequacy of implementation of the licensee’s formal arrangements for compliance with LC22 (modifications or experiment on existing plant) and LC28 (examination, inspection, maintenance and testing).  The inspection comprised of discussions with SL staff, and a sample of existing modifications and non-delivered maintenance.

In addition I also conducted follow up enquires on a recent event which occurred in the Waste Encapsulation Plant (WEP) and reported under INF1 2018/534.   

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 LC22 compliance inspection in WVP, I undertook a review of the relevant Sellafield procedures against the ONR guidance document for LC22, NS-INSP-GD-022 Revision 4.  From the areas sampled, I did not identify any significant shortfalls in the licensee’s formal arrangements for compliance with LC22 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 a number of ongoing modifications.  Whilst I judge that there were no significant shortfalls I did identify some areas for potential improvement in relation to the modification closure statements which was welcomed by the facility. 

Notwithstanding this, 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 22 (modification or experiment on existing plant).  I therefore consider that no formal action is required and an inspection rating of Green (No Formal Action) is merited for LC22.

Prior to the LC28 compliance inspection in WVP, I undertook a review of the relevant Sellafield procedures for non-delivery of scheduled maintenance 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 sampled a number of non-delivered maintenance activities.

Whilst the maintenance non-delivery process was only rolled out in WVP on the 19th March 2018, good progress has been made.  Although not formally required by the site process, the facility holds a daily meeting to review due maintenance to ensure that prompt delivery is managed.  I consider this approach to be good practice.

Within WVP, completion of the maintenance non-delivery form is undertaken by a suitable individual.  This is at variance to the SL process which requires the maintenance manager to complete the non-delivery form.  The reason this approach is taken is due to the fact that a lot of the time the maintenance manager is busy with other priority tasks.  This has been raised with the SL process owner and I will discuss this variance with the ONR corporate inspector.  Notwithstanding this, as the maintenance non-delivery form is accepted by the engineering manager and authorised by the head of operations, I am satisfied that there is suitable and sufficient oversight of this process.

I judge that, on the review of the sample of maintenance non-delivery forms at the time of this inspection, the licensee has adequately implemented its arrangements for compliance with Licence Condition 28 (examination, inspection, maintenance and testing).  I therefore consider that no formal action is required and an inspection rating of Green (No Formal Action) is merited for LC28.

On the 13 September 2018, I conducted follow up enquiries on the event reported under INF1 2018/534 which related to the snagging of a crane rope reeling drum on some nearby scaffolding.  I am satisfied that SL is taking the appropriate actions to address any learning from this event and that the circumstances of this event does not meet the ONR formal investigation criteria. 

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.