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’s Sellafield Programme. In accordance with this strategy, on 1-2 December 2015, a planned compliance inspection was carried out to determine the adequacy of SL’s compliance with Licence Condition 28 (LC 28) in the Sellafield Remediation and Decommissioning Projects (SR&DP) Operating Unit. The inspection focussed on the Redundant Active Handling Facility (RAHF) and the Active Handling Facility (AHF) within the SR&DP Operating Unit.
AHF and RAHF were selected because they are similar facilities in terms of age and construction and present a significant hazard and risk profile. AHF is operational and required to support SL’s high hazard and risk reduction programme and is leased to National Nuclear Laboratories (NNL), whilst RAHF is a redundant facility under care and maintenance. The inspection enabled a comparison between the asset care arrangements for each facility to be made and to verify that the arrangements are adequate and implemented appropriately.
This intervention is identified on the 2015/16 Sellafield PP3 Inspection Plan which covers the Decommissioning Division and SR&DP.
Our inspection was carried out over two days and comprised discussions with key SL and NNL staff and a review of relevant documentation. The ONR inspection team comprised the ONR Decommissioning Site Inspector, an ONR Specialist Inspector in civil engineering and an ONR Specialist Inspector in mechanical engineering from the ONR Sellafield programme.
This inspection was carried out in accordance with ONR’s inspection guidance for LC 28 for Examination, Inspection, Maintenance and Testing (EIM&T) as defined in NS-INSP-GD-028. During the inspection we examined the implementation of site arrangements for compliance with LC 28 in SR&DP and inspected two facilities, AHF and RAHF, to observe the current mechanical (ventilation system) and civil (building envelope) condition of the assets and SL’s plans for ongoing care and maintenance of these assets.
This was not a System Based Inspection (SBI), therefore, no such judgement was required.
We examined the implementation of SL’s LC 28 compliance arrangements within the AHF and RAHF and it was our opinion that the arrangements and their implementation were adequate. We considered that suitable work was being undertaken on asset care, and in most areas we judged it to be appropriately comprehensive. We did note some areas for improvement but considered these to be minor and would not affect the safety of the plants. SL’s Asset Lifecycle Model was judged to be a good tool to support compliance with the site’s new arrangements, and clearly demonstrated how SL applies governance to the implementation of Systems Engineering & Technical Basis of Maintenance (TBoMs) in SR&DP. It was our opinion that SL demonstrated good arrangements for the prioritisation of plants and systems for the planned implementation of Systems Engineering and Technical Basis of Maintenance (TBoMs) in SR&DP. The delivery of this programme is, however, slower than anticipated.
We examined the contractual relationship between NNL and SL for the accountability for maintenance in AHF and found the documentation adequate and that audit evidence supported SL’s claim that it was providing adequate oversight of the operational safety and maintenance of AHF plant.
During the plant inspections, we were encouraged to see visible improvements that had been made to the AHF building and the overall condition of the RAHF building. We determined that the ventilation systems in both facilities were being adequately maintained and that any known defects were being addressed in a timely manner. It was our opinion, however, that attention to the civil structure of both buildings would be required within the next five years in order to ensure that the building envelopes continue to provide their safety functions over the planned lifetimes of the facilities.
From the evidence sampled during this inspection, it is my opinion that for compliance against LC 28 an IIS rating of 3 (adequate) was appropriate. I made some recommendations where minor improvements could be made and where SL should provide further clarification. These were all accepted by SL and will be followed up during routine regulatory interactions.