Office for Nuclear Regulation

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Remote compliance inspection at the Low Active Effluent Management Group (LAEMG) facility

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 Low Active Effluent Management Group (LAEMG) facilities on the Sellafield Site. This intervention was targeted towards the Lagoon and the Segregated Effluent Treatment Plant (SETP) facilities within LAEMG due to their role in supporting essential ongoing operation of 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); 17 (Management systems); 23 (Operating rules); 26 (Control and supervision of operations); 28 (Examination, inspection, maintenance and testing (EIMT)); and, 36 (Organisational capability).

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 LAEMG, and if so, whether they have been complied with.

Interventions Carried Out by ONR

This inspection was carried out against LCs 10, 12, 17, 23, 26, 28 and 36. 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, 12 and 28.

The inspection began with question and answer teleconference between the inspection team, representatives from LAEMG 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 and in some cases clarifications were sought by separate phone calls. 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

In relation to LC 10 and LC 12, the inspection found that compliance with SL’s corporate arrangements was being maintained at the Lagoon and at SETP. In addition, the inspection found that limited use had needed to be made of a COVID-19 variation to SL’s corporate arrangements affecting these LCs.  Some advice was provided on future uses of the part of this variation dealing with extensions of authorisations of Suitably Qualified and Experienced Persons (SQEPs).  The inspection established that LAEMG is also now using the part of this variation dealing with reduced scope Duly Authorised Persons (DAPs) to control and supervise operations which may affect plant safety, although no reduced scope DAPs have yet been appointed.

It was clear that LAEMG had taken proactive steps in the early stages of the pandemic to move where possible into a quiescent or shutdown 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 was commendable.  However, we identified a shortfall with regard to LAEMG’s adoption and subsequent management of COVID-19 variations to SL’s corporate arrangements.  Relevant actions have been agreed: these are being tracked under a Level 4 (the lowest significance) Regulatory Issue relating to LC 17.

The inspection found that LAEMG was maintaining routine plant surveillance against its safe operating envelope in line with SL’s LC 23 arrangements.

The inspection provided assurance relevant to LAEMG’s control and supervision of operations, as required by LC 26.

LAEMG had focussed on essential nuclear safety significant maintenance, be that planned or reactive, and had made appropriate use of a COVID-19 variation to SL’s corporate arrangements to defer non-essential maintenance. 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.

The inspection team found evidence of several minor shortfalls with respect to LAEMG compliance with the corporate arrangements for LC 28. These related to quality of record keeping and ensuring that SQEP staff carry out and control and supervise maintenance. LAEMG were able to provide explanations in each case and mitigating circumstances existed due to the constraints of operating under the COVID-19 lockdown. However, these issues need to be addressed and will be followed up via a Level 4 Regulatory Issue, which LAEMG has agreed to take forward.

In relation to LC 36, LAEMG had undertaken proactive work to develop contingency plans in the event that challenges to Minimum Safe Manning Level arose.  These plans had not needed to be implemented during the pandemic.

Conclusion of Intervention

On the basis of the remote intervention evidence sampled at LAEMG in relation to LC 10, LC 12 and LC 28, I (Effluent & Encapsulation Plant Site Inspector) judged that SL had effectively implemented its arrangements for compliance with these LCs and have assigned an Inspection Rating of Green (no formal action required). Minor shortfalls identified under LC 28 will be followed up via a Level 4 Regulatory Issue.

We judged that there was an insufficiently sized sample of evidence to underpin an Inspection Rating for LC 17, LC 23, LC 26 & LC 36. However, for LC 23, LC 26 & LC 36, assurance was provided regarding how LAEMG was complying with SL’s arrangements and no matters were identified that would require formal follow-up. For LC 17, a Level 4 Regulatory Issue has been agreed with SL to track SL’s progress addressing a shortfall relating to LAEMG’s adoption and subsequent management of COVID-19 variations to SL’s corporate arrangements.