- Site: Winfrith
- IR number: 21-073
- Date: August 2021
- LC numbers: 28
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 Plant (HLWP) facility on the Sellafield Site. The purpose of the inspection was to confirm Sellafield Limited’s (SL) compliance to its corporate arrangements for licence condition 28 (Examination, Inspection, Maintenance & Testing (EIMT)).
Interventions Carried Out by ONR
On 12th August 2021, I carried out a planned licence condition compliance inspection of the High-Level Waste Plant (HLWP). The purpose of this inspection was to determine the adequacy of implementation of the licensee’s formal arrangements for compliance with LC28 (Examination, Inspection, Maintenance & Testing). This inspection comprised of discussions with SL staff, reviews of plant maintenance records and other documentation.
Explanation of Judgement if Safety System Not Judged to be Adequate
This was not a system based inspection; therefore, no judgement has been made to the adequacy of safety systems.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
Prior to the LC28 inspection, I undertook a review of the relevant Sellafield Ltd (SL) procedure against the ONR guidance document for LC28 (NS-INSP-GD-028 Rev. 5). From the evidence sampled, I did not identify any shortfalls in the licensee’s LC28 arrangements
To judge the adequacy of the implementation of these arrangements, I asked SL to explain how the facility manages non-delivery of scheduled maintenance. The maintenance manager was able to clearly articulate the process documented within the SL procedures. I was provided with the current list of non-delivered maintenance and sampled the justifications for key plant items. SL was able to adequately explain why these items had not been delivered and provided appropriate justification to demonstrate the continued safe operation of the plant.
I identified a discrepancy in SL’s Computer Maintenance Management System (CMMS) due dates for one tag as the task was not being fully completed on each occasion. SL explained that this was because the testing was on equipment common to both Vitrification Lines 1 and 2 and required aspects of both lines to be operational. However, it was uncommon for Lines 1 and 2 to be operating at the same time. SL had adequate documentation for the tasks, and they were being completed. I gave regulatory advice to SL that it should consider the benefits of separating the activities associated with this task into individual CMMS entries
I requested the training records for personnel involved in the approvals of Plant Maintenance Schedule (PMS) non-delivery. I identified a gap in the training records for three of the designated approvers responsible for sign-off of non-delivery maintenance. A training course had not been available due to Covid-19 restrictions. I consider this shortfall to be minor as there are other SQEP approvers with up to-date records. I provided regulatory advice to complete the training course at the earliest opportunity. SL’s NI&IO agreed to follow up on the training gap.
I requested an overview of the HLWP Asset Management arrangements. SL demonstrated how identified risks are incorporated within the asset management strategy. SL detailed the processes undertaken to implement asset management. SL provided evidence of how it is addressing identified asset risks.
Conclusion of Intervention
On the basis of the evidence sampled at HLWP in relation to LC 28, I judged that the licensee had effectively implemented its arrangements for compliance with the licence condition and have assigned an inspection rating of GREEN (no formal action required).