Office for Nuclear Regulation

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Remote compliance inspection focussed on the nuclear safety impact as a result of the covid-19 pandemic

Executive summary

Purpose of Intervention

In accordance with the Office for Nuclear Regulation’s (ONR’s) Sellafield Strategy, each year ONR performs a series of planned compliance inspections of selected licence conditions, targeted at those facilities with significant importance to nuclear safety.

This record describes the outcome from a planned compliance inspection at the Highly Active Liquor Evaporation and Storage (HALES) facility on the Sellafield Site. The purpose of the inspection was to confirm Sellafield Limited’s (SL) compliance to its corporate arrangements for licence conditions (LC): 10 (Training); 12 (Duly authorised and other suitably qualified and experienced (SQEP) persons); 23 (Operating rules); 26 (Control and supervision of operations); and 28 (Examination, inspection, maintenance and testing (EIMT)).

The inspection was undertaken remotely noting the limitations currently in place as a result of the coronavirus (COVID-19) pandemic. The inspection has been carried out in line with the ONR Sellafield Decommissioning, Fuel & Waste Division’s regulatory approach to the coronavirus situation.

In response to the pandemic, SL has recognised that its existing corporate compliance arrangements should remain unchanged and continue to be complied with where possible. Nonetheless, as a contingency, SL has developed variations to some of its corporate arrangements in order to introduce some flexibility, but in a way which still maintains compliance with legal obligations. SL has put in place variations to its corporate arrangements which affect its arrangements for compliance with LC 10, 12 and 28. Prior to this intervention, ONR has reviewed the relevant variations and is satisfied that they are adequate. This inspection has included consideration of whether the variations have been used at HALES, and if so, whether they have been complied with.

Interventions Carried Out by ONR

This inspection was carried out against LCs 10, 12, 23, 26 and 28. It sought to seek evidence of compliance in each case. However, it was recognised that given the remote nature of the intervention, a formal judgement of compliance would only be made should a sufficiently-sized sample of evidence be available under the circumstances. In this case, it was decided that a formal compliance rating was only possible against LCs 10, 23 and 28.

The inspection began with question and answer teleconference between the inspection team, representatives from HALES and the SL Nuclear Intelligence & Independent Oversight (NI&IO) internal regulator. This session was supported by evidence that had been requested in advance. Further evidence was requested and provided following this session. The inspection concluded with a follow-up teleconference. Regulatory judgements have been made based on the verbal answers and supporting documentary evidence.

Explanation of Judgement if Safety System Not Judged to be Adequate

This section is not applicable.

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

The inspection team found that HALES was maintaining compliance with the corporate arrangements for LCs 10 and 12. The coronavirus pandemic had led to some delays in the sign-off of some records and documents, but the licensee had made use of the variations to arrangements to secure approval by email where necessary.

It was clear that HALES had taken proactive steps in the early stages of the pandemic to move into a quiescent state and develop contingency plans for manning and supervising the facility in the event of potentially critical staff shortages. We consider that the work done here was commendable; however, we provided regulatory advice with regard to the further development of a revised quiescent minimum manning level and with regard to the appointment of duly authorised persons (DAPs).

The inspection found that HALES was maintaining routine plant surveillance against its safe operating envelope, and that where a fault had occurred, that it was detected and rectified in a timely manner in line with LC23 arrangements.

The inspection team found that HALES was compliant with the corporate arrangements for LC28. HALES had focussed on essential nuclear safety significant maintenance, be that planned or reactive, and had made appropriate use of the corporate process to defer non-essential activity. Where necessary, this had led to the shutdown/isolation of non-critical plant until the necessary maintenance or inspection can be carried out in future.

Conclusion of Intervention

On the basis of the remote intervention evidence sampled at HALES in relation to LCs 10, 23 and 28, the inspection team judged that the licensee had effectively implemented its arrangements for compliance with these licence conditions and has assigned an inspection rating of GREEN (no formal action required).

We judged that there was an insufficiently sized sample of evidence to underpin an inspection rating against LCs 12 and 26. However, assurance was provided regarding how HALES was complying with SL arrangements and no matters were identified that would require formal follow-up.