Office for Nuclear Regulation

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LC 26 Inspection – Fellside CHP LC 28 Inspection – Fellside CHP

Executive summary

Purpose of intervention

The Office for Nuclear Regulation (ONR) undertakes all regulatory interactions with Sellafield Limited (SL, the site licensee) against a strategy defined by the ONR Sellafield Programme.  My planned inspection schedule for the current regulatory year (covering April 2015 – March 2016), the content of which is guided by that strategy, identifies the Licence Conditions (LCs) that will be inspected over this period. 

This intervention was undertaken to determine if the Fellside Combined Heat and Power (CHP) facility is adequately implementing SL’s site-wide arrangements for compliance with Licence Conditions 26 and 28.  This facility was selected for this inspection because it supplies process steam to the Sellafield site. This is important to safety since steam is used to transfer radioactive liquids within process plants via steam ejectors, as well as being used for heating and evaporation functions.

Interventions Carried Out by ONR

Licence Condition 26 (LC26) requires the licensee to ensure that no operations are carried out which may affect safety except under the control and supervision of suitably qualified and experienced persons appointed for that purpose by the licensee.  This duty applies at Fellside even though it is managed under contract by PX Limited as the facility is on the licensed site and performs functions that affect safety.

 My inspection, which comprised discussions with SL and PX staff, and examination of plant documentation, focussed on the following areas:

Licence Condition 28 (LC28) requires the licensee to make and implement adequate arrangements for the regular and systematic examination, inspection, maintenance and testing (EIM&T) of all plant which may affect safety. This duty applies to SL even though Fellside is managed under contract as the facility is plant affecting safety.

My inspection, which comprised discussions with SL and PX staff, examination of plant documentation, and physical inspection of the facility, focussed on the following areas:

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable; this was not a Safety System inspection.

Key Findings, Inspector's Opinions and Reasons for Judgements Made

I consider that SL’s arrangements for compliance with LC 26 have been effectively implemented at Fellside.  There were a number of areas of good practice, and a number of improvements that could reasonably be made, all of which were accepted by the licensee.

I consider the facility’s implementation of the site’s arrangements for LC26 is good in many areas.  For instance there is a good system for supervising and controlling work activities through risk assessments, method statements and isolation arrangements. This is however offset by some minor shortcomings in housekeeping and behavioural safety at the facility. For these reasons, on balance, I consider the inspection merits an IIS rating of 2 (Good standard), against LC26. None of these shortcomings however present any safety concern.  

I consider that SL’s arrangements for compliance with LC 28 have been effectively implemented at Fellside.  There were a number of areas of good practice, and a number of improvements that could reasonably be made, all of which were accepted by the licensee.

 I consider the facility’s implementation of the site’s arrangements for LC28 is good in many areas.  For instance there is a good level of verification and peer review throughout the arrangements in the areas I sampled. This is however offset by some weaknesses relating to the MAXIMO Plant Maintenance Schedule system. For these reasons, on balance, I consider the inspection merits an IIS rating of 3 (Adequate), against LC28.  Furthermore, I am satisfied that the weaknesses relating to the MAXIMO system do not present any safety concern. 

Conclusion of Intervention

My findings were shared with, and accepted by, the licensee as part of normal inspection feedback. No ONR Regulatory Issues were raised as a result of this inspection.