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 November 2018.
On 15th November 2018, I, a site inspector in the SDFW Division, accompanied by the site inspector for the operational waste facilities, carried out two planned licence condition compliance inspections of the High Level Waste Plants (HLWP). The purpose of these inspections was for the ONR to determine the adequacy of implementation of the licensee’s formal arrangements for compliance with LC12 (duly authorised and other suitably qualified and experienced persons) and LC26 (control and supervision of operations). The inspection comprised of discussions with SL staff, a review of plant documentation and a review of training records.
In addition we also conducted follow up enquires on recent events which occurred in the HLWP and were reported under INF1 2018/507, 622, 691 and 702. INF 2018/507 and 622 were in connection to the non-delivery of maintenance process and duly authorised persons responsibilities. INF 2018/691 and 702 were in connection to the control of contractors carrying out operations.
The site inspector for the operational waste facilities also attended the effluents and encapsulation quarterly review meeting.
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.
Prior to the LC 12 and LC26 inspection in the HLWP, I undertook a review of the relevant Sellafield procedures against the ONR guidance documents for these licence conditions, NS-TAST-GD-027 Revision 5 and NS-INSP-GD-026 Revision 3. From those areas sampled, I did not identify any significant shortfalls in the licensee’s formal arrangements for compliance with LC 12 or LC26 which would prompt an inspection of those arrangements earlier than currently planned.
For the LC12 inspection I focussed on the Duly Authorised Persons (DAP), Appointed Suitably Qualified and Experienced Persons (ASQEP), Superintending Officers (SO) and Nominated Representatives (NR) in connection with INF1 2018/507, 622, 691 and 702. During the review of the SO and NR role profiles for two individuals it was identified that the same two training courses had not been completed as required by the role profiles and no waivers were in place. Further discussion with the SL training team identified that these were new training courses added to the role profiles and this is a site wide issue for the SO and NR roles for control of contractors.
This is the same issue as discovered during a previous LC11 inspection in the Highly Active Liquor Evaporation and Storage (HALES) facility which had resulted in an enforcement letter being sent to Sellafield Limited. In light of this, ONR will pursue this shortfall at a corporate level.
On the basis of evidence sampled at the time of this inspection, I judge that the licensee has not adequately implemented its arrangements for Licence Condition 12 (duly authorised and other suitably qualified and experienced persons). I therefore consider that an inspection rating of Amber (Seek Improvement) is merited.
For the LC26 inspection I focussed on the control of contractors in connection with the INF1s 2018/691 and 702 and the non-delivery of maintenance process in connection with INF1 2018/507 and 622. Overall I was satisfied that the appropriate processes were in place in the HLWP for the non-delivery of maintenance and control of contractors.
It was noted that within HLWP procedures there is a requirement to carry out a six monthly audit to ensure that compliance with the Clearance Certificates has been maintained. There was no evidence that these audits had been carried out and as a result a level 4 regulatory issue has been raised.
Notwithstanding this, overall 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 26 (control and supervision of operations). I therefore consider that the required standard was met and an inspection rating of Green is merited.
As a result of my follow up enquiries on the events reported under INF1s 2018/507, 622, 691 and 702 I am satisfied that SL are taking the appropriate actions to address any learning and that the events do 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.
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.