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Sellafield planned compliance inspection of LC 23 (Operating rules) and LC 24 (Operating instructions)

  • Site: Sellafield
  • IR number: 21-064
  • Date: August 2021
  • LC numbers: 23, 24

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.

The purpose of this inspection was for ONR to determine the adequacy of implementation of SL’s arrangements for compliance with LC 23 (Operating rules) and LC 24 (Operating instructions) within Waste Packaging and Encapsulation Plant (WPEP) which is part of Low Active Effluent Management Group (LAEMG).

The overall adequacy of SL's site-wide LC 23 and LC 24 arrangements is considered separately in other ONR interventions.

Interventions Carried Out by ONR

I, the Site Inspector for Effluent and Encapsulation Plants supported by two Fault Studies specialist inspectors, carried out a planned LC 23 & LC 24 compliance inspection at WPEP. The inspection focused on:

  • WPEP’s implementation of the SL arrangements for LC 23;
  • WPEP’s implementation of the SL arrangements for LC 24.

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 as well as local Sellafield specific arrangements.

The inspection comprised discussions with SL staff, a review of records, 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 WPEP (LAEMG) has adequately implemented the Sellafield Limited arrangements for LC 23 and LC 24.

Through the process of sampling the supplied management arrangements, operating instructions, records, and discussion with plant staff. I conclude that WPEP (LAEMG) provided evidence of the following:

  • That Operating Rules are clearly identified against the associated faults in the Continued Operational Safety Case and are correctly reflected in the facility’s Clearance Certificate (CC).
  • The CC clearly identifies the provenance of the requirements for the rOIs, outlining what it is, the safety function it fulfils, and to what plant states or operations it applies.
  • The safety case requirements are appropriately implemented in instructions.
  • Instructions are subject to review and that there is a programme to manage the backlog of beyond review date instructions.
  • Appropriate arrangements exist for handovers recording and logging.
  • Adequate arrangements exist for alarm response instructions.
  • There was not a clear link between Operating Assumptions (OAs) to the relevant operating instructions in the CC or via another means through which compliance is ensured.
  • Some OAs are framed as instructions rather than limits or conditions.
  • An example of a significantly out of date instruction was found in use on the plant. However, this was later established to not strictly be required by the safety case.
  • Examples of inadequate or absent risk assessments were found associated with instructions.
  • SLs had recently revised arrangements for authoring and reviewing of instructions. This revision identified specific training requirements that were found to be incomplete within LAEMG. However, appropriate training is in development.
  • Several Cat 2 instructions were found with record retention requirements inconsistent with SLs arrangements.

In response to the observed shortfalls SL have raised Condition Reports (CRs) within the existing company improvement process. Follow up actions by SL will include internal assurance activities to address these findings.

The plant/control room walkdown passed without major observations. Overall, the plant gave the impression of being in good state, tidy, and clean. However, some low-level shortfalls were observed:

  • Physical nuclear safety dashboard/Team leader notice board was out of date/not in sync with electronic version which is used for daily briefing under COVID19 arrangements. This had the potential to provide misleading information.
  • The team leaders log contained several long-standing plant defects.
  • The control room notice board displayed several long-standing alarms due to system defects. While these were not required for the normal operation and not safety related, they are a potential operator distraction.
  • Control room display’s electrical back panel cabinets were open/not locked, contrary to the safety markings on them.

These findings were shared with, acknowledged, and accepted by LAEMG’s management as part of normal inspection feedback. A level 4 (lowest level) regulatory issue (8948) has been raised to track follow up actions. In my judgement, these findings are not significant enough to adversely change the rating for LC 23 and LC 24.

Conclusion of Intervention

Based on the evidence sampled at the time of the inspection, I judge that WPEP (LAEMG) has adequately implemented the SL arrangements for LC 23 and LC 24. It is my opinion that an inspection rating of Green (no formal action) is therefore appropriate for both licence conditions.