- Site: Sellafield
- IR number: 21-035
- Date: June 2021
- LC numbers: 34
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 2021/22, identifies the Licence Conditions (LCs) that will be inspected during this period. This intervention was postponed from the 2020/21 plan due to the COVID-19 pandemic and national lockdown.
The purpose of this inspection was for ONR to determine the adequacy of implementation of SL’s arrangements for compliance with LC 34 (Leak and Escape of radioactive material and radioactive waste) within Low Active Effluent Management Group (LAEMG).
The overall adequacy of SL's site-wide LC 34 arrangements is considered separately in other ONR interventions.
Interventions Carried Out by ONR
I, the Site Inspector for Effluent and Encapsulation Plants supported by a Nuclear Liabilities Regulation specialist inspector, carried out a planned LC 34 compliance inspection at LAEMG. The inspection focused on:
- LAEMG’s implementation of the SL arrangements for LC34;
- LAEMG’s arrangements with respect to a leak and escape of radioactive material and radioactive waste at Salt Evaporator and Medium Active Storage (SEMAS).
The inspection comprised discussions with SL staff, a review of records, the sampling of information contained within electronic databases and other documentation and a plant 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
I found that LAEMG has adequately implemented the Sellafield Limited arrangements for LC34, including, where applicable, variations made in response to the COVID-19 pandemic and national lockdowns.
Through the process of sampling the supplied management arrangements, operating instructions, records, and discussion with plant staff. LAEMG provided sample evidence of the following:
- That LAEMG has local arrangements to support compliance with LC34,
- A sample of training records in relation to Duly Authorised Persons (DAP) and operators that demonstrated they had attended a range of training courses covering leakage and escape requirements.
- That the safety functions related to leakage and escape of radiological material can be traced from the safety case through to operating instructions and maintenance requirements.
- That operator rounds are performed and recorded to ensure compliance with the required availability of safety related equipment
- That equipment and plant used to detect leaks and escapes were being maintained in accordance with the Examination, Inspection, Maintenance and Testing (EIMT) schedule.
The following shortfalls were identified:
- LAEMG could not demonstrate full compliance with the training requirements set out in the SL mandatory standard for LC34.
- A scaffold was found to be in use beyond its specified inspection and decommissioning dates. SL addressed this matter immediately.
- A minor non-compliance with COVID19 variations with respect to record keeping of electronic sign-off of Operational Decision Making (ODM) papers.
SL accepted these findings and a level 4 (lowest level) regulatory issue has been agreed to track follow up actions with respect to LC34 training. Since other relevant training was found to be in place and there was no evidence of a weakness in competence, in my judgement this is not significant enough to affect the inspection rating.
In response to the shortfall with respect to inspection of scaffolding SL have provided immediate follow up improvements and I will continue to monitor this through my routine regulatory engagements. In my judgement, this finding does not affect the rating for LC34 because it does not fall under this licence condition.
The findings were shared with, acknowledged, and accepted by LAEMG’s 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 LAEMG has adequately implemented the SL arrangements for LC 34, and it is my opinion that an inspection rating of Green (no formal action) is therefore appropriate.