- Site: Sellafield
- IR number: 20-020
- Date: July/August 2020
- LC numbers: 10, 11, 24, 28
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, Decommissioning, Fuel and Waste (SDFW) Division. The planned inspection schedule for 2020/21, updated as a result of the COVID-19 Pandemic, identifies the Licence Conditions (LCs) that will be inspected during this period.
The purpose of this inspection was for ONR to determine the adequacy of implementation of SL’s arrangements for compliance with LC 10 (Training), LC 12 (Duly authorised and other suitably qualified and experienced persons), LC 24 (Operating Instructions), LC 26 (Control and supervision of operations) and LC 28 (Examination, Inspection, Maintenance and Testing) on Encapsulation Plant, focusing on the restart activities for Magnox Encapsulation Plant (MEP).
The overall adequacy of SL's site-wide LC compliance arrangements is considered separately in other ONR interventions.
Interventions Carried Out by ONR
I carried out planned remote LC 10, 12, 24, 26 and 28 compliance inspections of Encapsulation Plant. The inspection focused on the evidence supporting readiness for restart of active operations at MEP after the forced outage in response to the COVID19 pandemic. The following areas were sampled:
- The evidence in support of the Management Safety Committee (MSC) paper used by SL to confirm readiness for MEP to restart operations;
- Records that operators identified in the Minimum Safe Manning Levels (MSML) document are suitably trained and experienced. In particular, with respect to emergency arrangements. (LC 10 with additional assurance with respect to LC 11);
- The package of training used to re-familiarise staff returning to work and ensure appropriate awareness of COVID-19 social distancing arrangements (LC 10 and LC 26);
- The Control and Supervision Organisation Baseline (LC 12);
- The arrangements for appointment of Duly Authorised Persons (DAPs) (LC 12);
- The review of operating instructions and the implementation of variations to the SL arrangements to enable the use of instructions beyond their review date (LC 24);
- Setting to work briefings and walkdowns of plant for DAPs and operators prior to restart of MEP active operations (LC 26);
- Daily logs, shift handover and nuclear safety dashboards (LC 26);
- Control of planned maintenance non-delivery (LC 28);
- Maintenance and inspection records for lifting equipment, radiological monitoring equipment and safety mechanisms (LC 28);
- Training records for operatives conducting maintenance important to safety (LC 10 and LC 28).
The inspection comprised remote document review in advance of discussions with SL staff and review of records requested during telephone meetings. SL’s internal regulator was in attendance for the duration of the inspection.
Explanation of Judgement if Safety System Not Judged to be Adequate
Not applicable since this was not a safety system based inspection.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
No significant matters were identified as requiring immediate regulatory attention in relation to the implementation of the LC 10, LC 12, LC 24, LC 26 and LC 28 arrangements at Encapsulation plant. At the time of the inspection no evidence that a review of the impact of deferral of emergency exercises and drills had been conducted was available. A level 4 issue has been raised to ensure that this is made provided to ONR to sample outside of this intervention. A minor shortfall with respect to DAP sign off of maintenance of Safety Mechanisms will be followed up by the SL internal regulator.
My findings were shared with, Encapsulation Plant management as part of normal inspection feedback.
Conclusion of Intervention
On the basis of the evidence sampled at the time of the inspection, I judge that Encapsulation Plant has adequately implemented SL’s arrangements for LC 10, LC 12, LC 26, and LC 28. Noting the ONR guidance on inspection ratings, it is my opinion that an inspection rating of Green (no formal action) is merited.
As a result of the extended period of shutdown the sample achieved with respect to LC 24 was not sufficient to provide a formal rating. However, assurance of compliance was gained and no significant shortfalls identified.
A level 4 regulatory issue has been raised to facilitate tracking of review and revision to LC11 emergency exercises and drills that was not available at the time of the inspection.