Office for Nuclear Regulation

Sellafield - LC7, LC12 and LC26 compliance inspections

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 January 2019. 

Interventions Carried Out by ONR

On 15 January 2019, I, the site inspector for the operational waste facilities, carried out a planned licence condition compliance inspection of a number of plants in the remediation value stream.  The purpose of this inspection was for the ONR to determine the adequacy of implementation of the licensee’s formal arrangements for compliance with LC7 (incidents on site) with respect to the recording, monitoring and close out of any actions arising out of event investigations.  These inspections comprised of discussions with SL staff and reviews of investigations and other documentation.

On the 16 January 2019 I carried out planned licence condition compliance inspections within the Highly Active Liquor Evaporation and Storage (HALES) facility.  The purpose of these inspections was for the ONR to determine the adequacy of implementation of the licensee’s formal arrangements for compliance with L12 (duly authorised and other suitably qualified and experienced persons) and LC26 (control and supervision of operations) with respect to maintenance.

I also conducted follow up enquires on two recent events; one which occurred in the engineered drum store and subsequently reported under INF1 2018/802 and one which occurred in the High Level Waste Plants (HLWP) and reported under 2019/2.   

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 LC7 inspection, I undertook a review of the relevant Sellafield procedure against the ONR guidance document for LC7, NS-INSP-GD-007 Revision 4.  From the areas sampled, I did not identify any significant shortfalls in the licensee’s formal arrangements for compliance with LC7 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 identified a number of recent events in advance of this inspection.  I then reviewed the evidence for monitoring and close out of the actions arising out of these investigations.

From the sample I reviewed, I judged that the actions identified were appropriately managed and adequate closure statements were presented and recorded on the company database.  I did however identify some areas for potential improvement. These related to the use of the company database for actions outside of investigations and the process for extending the due dates of actions which I advised the facility on accordingly. Notwithstanding this, I was satisfied that the actions are being appropriately raised, tracked and closed. 

I therefore judged that the licensee has adequately implemented its arrangements for recording, monitoring and close out of any actions arising out of event investigations under Licence Condition 7 (incidents on site).  I therefore consider that the required standard was met and an inspection rating of Green (No Formal Action) is merited.

Prior to the LC12 and LC26 inspection, I undertook a review of the relevant Sellafield procedures against the ONR guidance document for these licence conditions; NS-INSP-GD-012 Revision 1 and NS-INSP-GD-026 Revision 3 respectively.

From the areas sampled, I did not identify any significant shortfalls in the licensee’s formal arrangements for compliance with LC7 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 the control and supervision of maintenance activities within HALES.  I sampled the training records of two Maintenance Team Leaders (MTLs) to ensure that they had completed the mandatory training for that role and had been appropriately appointed in writing.  I also interviewed them to confirm that they were undertaking their control and supervision roles in accordance with the SL corporate arrangements. 

Both the MTLs were able to clearly articulate how the various maintenance tasks were allocated based on the experience of the maintenance team member and the complexity of the task.  They were also able to explain how they carry out their responsibilities for supervising the team.   I considered they were both very capable within their roles and their answers clearly demonstrated that they understood the control and supervision requirements that went with that role.

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 12 (duly authorised and other suitably qualified persons) and LC26 (control and supervision of operations) with areas of best practice.  I therefore consider that the required standard was met and an inspection rating of Green (No Formal Action) is merited for both licence conditions.

As a result of my follow up enquiries on the events reported under INF1 2018/802 and INF1 2019/2, 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.

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.