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); 11 (Emergency arrangements); 12 (Duly authorised and other suitably qualified and experienced (SQEP) persons); 24 (Operating instructions); and 28 (Examination, inspection, maintenance and testing (EIMT)).
Due to the current coronavirus (COVID-19) pandemic risks, the intervention followed a blended approach involving a mixture of some remote engagement supplemented by some face-to-face interaction and an on-site inspection by the ONR Site Inspector. The inspection has been carried out in line with the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division’s regulatory approach to the COVID-19 pandemic.
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. 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.
This inspection was carried out against LCs 10, 11, 12, 24 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 11, 24 and 28.
The inspection began with question and answer teleconference between the inspection team, representatives from HALES and the SL NI&IO Internal Regulator. This session was supported by evidence that had been requested in advance. In addition, the Site Inspector and the Internal Regulator undertook a visit to the facility. This included face-to-face discussions with plant personnel. Further evidence was requested and provided following this session. The inspection concluded with a follow-up teleconference. Regulatory judgements have been made based on all of the information gathered during the course of the intervention.
The inspection focussed on the nuclear safety aspects associated with the intended resumption of Evaporator D operations by the dutyholder in the coming weeks and was structured into three themes:
The impact of coronavirus has been considered during the execution of this inspection. This has included consideration of the lockdown/partial shutdown period, as well the risks of a future resurgence of the virus, and the impact of coronavirus risk control measures including on the delivery of nuclear safety. The appropriate implementation of coronavirus infection control measures, in terms of the individuals’ health and wellbeing, has also been considered, as and where possible, as part of this inspection.
This section is not applicable.
With regard to Theme 1, we are of the opinion that personnel were ready for restart. We also reviewed the restart instruction and consider that it was well written and maintained. Engagement with some of control room personnel showed that they were knowledgeable, responsible and confident that restart could be achieved safely. They had continued to monitor the plant during its period of shutdown and were actively re-familiarising themselves ahead of returning to operation.
With regard to Theme 2, we are of the opinion that local emergency arrangements remain adequate. A review of a sample of emergency instructions found them to be well written and maintained. Whilst the shutdown and lockdown had limited the scope for practical emergency exercising, walkdown drills and exercises had continued for all personnel and, on questioning, staff were knowledgeable on emergency arrangements.
With regard to Theme 3, we are of the opinion that HALES was working towards ensuring that the maintenance backlog due to the shutdown and lockdown was being appropriately resolved. We examined the non-delivery of some items of maintenance and were content with the rationales provided and verified that the appropriate process for the implementation of non-delivery was being followed. However, we advised that the management of some of the maintenance information, and completeness of the record of the rationales for non-delivery, should be strengthened.
On the basis of the evidence in relation to LCs 11, 24 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 10 and 12. However, assurance was provided regarding how HALES was complying with SL arrangements and no matters were identified that would require formal follow-up.