Date(s) of inspection:
- May 2023
Aim of inspection
This was a joint ONR and Environment Agency (EA) compliance inspection of the Examination, Inspection, Maintenance and Testing (EIMT) arrangements at the Highly Active Liquor Evaporation and Storage (HALES) facility and the High Level Waste Plants (HLWP).
Subject(s) of inspection
- LC28 – Examination, inspection, maintenance and testing – Rating: Amber
Key findings, inspector’s opinions and reasons for judgement made
Acknowledging the findings that are set out within the ONR’s Chief Nuclear Inspector’s themed inspection on the management of ageing facilities report (ONR-RA-REP-21-009). I targeted this joint ONR and EA LC28 inspection on the adequacy of the arrangements for asset management and maintenance at the Sellafield’s Ltd HALES and HLWP facilities.
I carried out a review of the asset management system and of the 134 Plant Based Systems across the two facilities that are classed as safety significant, approximately 50 had no assigned Reliability Engineer and a number of them had not had the full system health report (SHR) process applied for over 3 years. For these systems, there is the potential that the scopes and improvements are not being progressed and that degradation mechanisms are not being monitored. The root cause of this is a resource shortfall in engineers but it is acknowledged that this is a site wide issue that the Sellafield Ltd enterprise is currently working on a number of solutions to address. The facilities were open and honest about the shortfalls and are working on a strategy to cover all the Plant Based Systems whilst prioritising their focus and available resource on the highest risk areas. I have no concern that the facilities are not safe today, but the shortfall is in the future proofing of the entirety of the plant and the long term strategy for the condition of the facilities assets. A Level 3 Regulatory Issue will be raised to track the implementation of the plants’ strategy to ensure that all systems are covered by a competent authority and that those assets of greatest risk are prioritised with the available resource.
I undertook a review of the maintenance records for both facilities and noted that there were significant backlogs on maintenance that were not trending downwards. The Maintenance Engineers were open and honest about the backlogs and had undertaken analysis to identify the root causes of the backlogs and blockers to maintenance. For the HLWP there is a plan in place to address the backlog and for the HALES plant they had identified a number of areas for improvement but had not at the time of the inspection actioned a plan. A level 3 Regulatory Issue will be raised on the facilities to produce and implement an improvement plan to address the maintenance backlogs on both facilities.
I undertook a sample of maintenance records that had been completed in April 2023 for both facilities and on the basis of the records sampled, I was satisfied that maintenance was being carried out to a good standard and records were adequately populated with readings and signatures.
Overall, based on the shortfalls seen in asset management and the significant backlogs in maintenance, I judge that an inspection rating of Amber (seek improvement) is appropriate against Licence Condition 28 and a Level 3 Regulatory Issue will be raised to address these shortfalls.
I have taken these shortfalls through ONR’s Enforcement Management Model to decide if any further follow up action is required beyond the Level 3 Regulatory Issue and concluded that the proportionate enforcement action was to provide Regulatory Advice. I provided Regulatory Advice in relation to these shortfalls at the end of the inspection which was accepted by the Head of Operations for both HLWP and HALES.