Office for Nuclear Regulation

Blended compliance inspection in advance of the resumption of WVP Line 3 vitrification operations

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 High Level Waste Plants (HLWP) facility on the Sellafield Site. The purpose of the inspection was to inspect Sellafield Limited’s (SL) compliance with its corporate arrangements for licence conditions (LC): 10 (Training); 11 (Emergency arrangements); 24 (Operating instructions); and 28 (Examination, inspection, maintenance and testing (EIMT)).

Due to the current coronavirus (COVID-19) pandemic, the intervention followed a blended approach involving a mixture of remote engagement supplemented by 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. This inspection has included consideration of whether the variations have been used at HLWP, and if so, whether they have been complied with.

Interventions Carried Out by ONR

This inspection was carried out against LCs 10, 11, 24 and 28 seeking evidence of compliance in each case. The inspection began with a question and answer teleconference between the inspection team, representatives from HLWP and the SL Internal Regulator. This session was supported by evidence that had been requested in advance. In addition, the Site Inspector and the SL Internal Regulator undertook an inspection of the facility and this included discussions with plant personnel. Further evidence was requested and provided following the plant inspection. The inspection concluded with a follow-up teleconference. Regulatory judgements have been made based on the information gathered during the course of the intervention.

The inspection focussed on the nuclear safety aspects associated with the intended resumption of Waste Vitrification Plant Line 3 (WVPL3) operations and was structured into three themes:

The nuclear safety impact of coronavirus was considered as part of the inspection with assurances sought in relation to measures in place should there be a resurgence of the virus. The implementation of coronavirus infection control measures, in terms of the individuals’ health and wellbeing was also considered during the inspection.

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

With regard to Theme 1, I judged that personnel were ready for restart. The restart instruction was reviewed and found to be well written and maintained. Engagement with operations 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 re-familiarising themselves ahead of returning to operation.

With regard to Theme 2, I judged that the local emergency arrangements were adequate. Whilst the shutdown and lockdown had limited the scope for practical emergency exercising, walkdown drills had continued for all personnel.  Facility operators were knowledgeable on emergency arrangements and understood their respective roles and responsibilities.

With regard to Theme 3, I judged that HLWP is adequately addressing the maintenance backlog that has arisen due to the shutdown and lockdown. HLWP are planning to deliver all maintenance for safety related items, required for WVPL3 operations, prior to re-start.  I further sampled an item of maintenance that had recently been completed and also examined the non-delivery justification for an item of maintenance and I was content with evidence provided.

Conclusion of Intervention

On the basis of the evidence in relation to LCs 10, 11, 24 and 28, I judged that the licensee had effectively implemented its arrangements for compliance with these licence conditions and have assigned an inspection rating of GREEN (no formal action required).

The evidence sampled in relation to LC 10 highlighted an area for improvement and a Level 4 Regulatory Issue has been raised to address this minor shortfall.