Office for Nuclear Regulation

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To conduct a LC22 compliance inspection at the Sellafield site Fuel Handling Plant

Executive summary

Purpose of intervention

This intervention was undertaken on 5 August 2015 on the Fuel Handling Plant (FHP) at Sellafield Limited’s nuclear licensed site at Sellafield in Cumbria.

Inspection of Licence Condition (LC) compliance at nuclear licensed sites forms a significant part of ONR’s activities.  ONR’s Sellafield Programme has defined a programme of system inspections and LC compliance inspections to be undertaken on the Sellafield site, this is a key aspect of ONR’s regulatory strategy (for the Sellafield site).  Undertaking this intervention is consistent with this strategy, and is identified on ONR’s PP4 inspection plan which covers Sellafield Limited’s Magnox Operating Unit. This facility, operated by the licensee Sellafield Ltd (SL), was considered to be an appropriate target for an intervention because I was seeking evidence that SL had complied with an Improvement Notice.

Interventions Carried Out by ONR

LC22 ‘Modification or experiment on existing plant’ requires the licensee to make and implement adequate arrangements to categorise and control all modifications and experiments, as defined in LC1(1), on existing plant or processes that have the potential to affect safety directly or indirectly. 

I completed the compliance inspection (comprised office based discussions and a plant walk down) against LC22 in accordance with the following ONR guidance:

The primary focus of the inspection was to confirm that SL had complied with Improvement Notice I/2013/ONR/MK/001 requiring improvements to prevent inadvertent exposure to ionising radiation during flask maintenance gamma gate operations within FHP, and in so doing, confirm on a sampling basis that SL had implemented their extant LC22 compliance arrangements.

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A.  This was not a safety system inspection.

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

Improvement Notice I/2013/ONR/MK/001 requires SL to make improvements to prevent inadvertent exposure to ionising radiation during flask maintenance gamma gate operations within FHP by 31st August 2015.  SL divided the necessary improvement work into two distinct phases (1 and 2).  I confirmed both were complete through examination of documentary evidence followed by a plant walk down to verify the plant had been modified in line with the evidence.  Delivery of the improvements has resulted in a reduction in the risks associated with the operations of the flask maintenance gamma gate.  SL has delivered the necessary improvements earlier than the Improvement Notice due date, which is 31st August 2015; this is commendable.

For the LC22 compliance inspection element of this intervention I focussed on two Plant Modification Proposals (PMPs) which justified the plant modifications necessary to deliver phases 1 and 2.  Specifically I sought to confirm SL was complying with its own LC22 arrangements and was seeking to close out both PMPs in a timely manner.  I was satisfied, based on my sample, that SL was complying with its LC22 arrangements, and I found no deficiencies. 

In my opinion SL met the requirements of ONR’s LC22 guidance; I therefore judged an IIS rating of 3 (adequate) to be appropriate. 

Conclusion of Intervention

No issues were raised as a result of this intervention.  Based on the evidence gathered, no significant matters have been identified that are likely to impact on nuclear safety on the Sellafield site at this time.