On the 12th October 2016 the Office for Nuclear Regulation (ONR) undertook an intervention on the Sellafield site to inspect Sellafield Ltd's (SL) readiness to commence demolition of the first generation reprocessing plant (FGRP) stack and gain evidence to support ONR's permissioning of this activity. This intervention record (IR) records ONR's readiness inspection concerning the licensee's implementation of their arrangements. It will be used as a part of ONR's overall consideration when making a permissioning decision concerning ONR's regulatory hold point placed on the FGRP stack demolition activity, which will be recorded in ONR's Project Assessment Report ONR-SDFW-PAR-16-025.
The purpose of the intervention was to inspect SL's implementation of their Licence Condition (LC) arrangements under LC22 "Modification or Experiment on Existing Plant". The intervention sought to gain assurance that the SL FGRP stack demolition project is in a state of readiness to safely commence demolition activities which also include the ascent, configuration and subsequent descent of a Self-Climbing Platform (SCP) utilised as an access platform from which the demolition operation is conducted.
This intervention is in accordance with ONR's Sellafield strategy which has an emphasis on the safe and timely delivery of hazard and risk reduction on the Sellafield site.
Interventions Carried Out by ONR
The primary focus of this intervention was to inspect the FGRP stack demolition projects plant, processes and people and assess their readiness to safely commence demolition activities. The ONR inspection comprised of desktop based discussions, on-plant inspections and dialogue with the stack demolition project operatives at the site of planned activities. I have focused my inspection on the following factors that I consider to be key from a perspective of stack demolition project readiness for permissioning:
This inspection focused upon examining evidence in support of the above and on how the supporting arrangements implement the safety case limits and conditions. I have inspected against LC22 (1) which requires the Licensee to 'make and implement adequate arrangements to control any modification or experiment carried out on any part of the existing plant or processes which may affect safety', using ONR's technical inspection guide (TIG) NS-INSP-GD-022; this represents relevant good practice. The supporting TIG outlines the expectations with regard to implementation of the modification. From a project readiness perspective the following are relevant: potential for impairment of the safety functionality or reliability of systems structures and components; emergency arrangements, plant configuration and records.
It should be noted that, for the purposes of assessing project readiness, an assessment by the ONR Human Factors Specialist Inspector discussing procedures, training and supervision, is the subject of a separate intervention record.
N/A - This was not a safety system inspection.
Based on the evidence sampled during this intervention, we have judged SL's implementation of its LC arrangements as Green (no formal action) for LC 22. A number of shortfalls were identified which, in the main, are self-identified by SL and are a reflection of the SL project's position in terms of their preparations for stack demolition. SL has a robust readiness governance process which has yet to complete and will address much of the aspects identified by ONR during this inspection. Where appropriate we will seek assurances from the SL Internal Regulator (IR) that the governance process has been appropriately applied and completed.
Shortfalls identified were acknowledged by SL, specifically:
Based on our sample and the evidence gathered, we judged SL's implementation of LC22 on the FGRP stack demolition project to be green (no formal action).
In relation to SL's state of readiness for the proposed activities I conclude that, upon completion of the aforementioned shortfalls, that the inspection has confirmed SL have adequately implemented appropriate plant, processes, training and supervision of operations on the SCP.