Office for Nuclear Regulation

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LC 10 & 28 Compliance Inspection - Sellafield Ltd Utilities Separation Area Ventilation, Sellafield

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, Decommissioning, Fuel and Waste (SDFW) Programme.  The planned inspection schedule for the current regulatory year (covering April 2016 - March 2017), the content of which is guided by that strategy, identifies the Licence Conditions (LCs) that will be inspected over this period.

This planned intervention was undertaken to determine if SL's Utilities Separation Area Ventilation (SAV) facility is adequately implementing SL's site-wide arrangements for compliance with Licence Condition 10 (training), and Licence Condition 28 (examination, inspection, maintenance and testing). The intervention focussed on the Utilities SAV facility as it is important to nuclear safety as it enhances the confinement afforded by a number of donor facilities, plant, equipment and buildings. Specifically, SAV removes airborne particles from discharged air to ensure emissions comply with the site's aerial discharge limits and are as low as reasonably practicable, as well as assisting in the provision of a suitable working environment for personnel and equipment in the facilities it services. The continued safe operation of the SAV facility is also important in supporting SL's overall hazard and risk reduction activities across the Sellafield site.

The overall adequacy of SL's site-wide arrangements is considered separately in other ONR inspections.

Interventions Carried Out by ONR

Licence Condition 10 (LC 10) requires the licensee to make and implement adequate arrangements for suitable training for all those on site who have responsibility for any operations which may affect safety.

My inspection, which comprised discussions with SL staff, examination of plant documentation, and inspection of facilities and equipment, focussed on SL's:

My inspection, which comprised discussions with SL staff, examination of plant documentation, and inspection of facilities and equipment, focussed on SL's:

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable; this was not a safety system based inspection.

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

I consider the licensee is in breach of LC28 requirements as its examination, inspection, maintenance and testing arrangements are not fully established.  Specifically I found numerous examples of incomplete risk assessments and of maintenance instructions that require validation and SL approval.  I note however, that the licensee is aware of these shortfalls and already had plans in place (under its integrated work management plan) to address them. Nevertheless, I consider that the shortfalls are important enough to assign an inspection rating of Amber (seek improvement) against LC28.

I consider the licensee is also in breach of LC10 requirements as its minimum manning safety levels arrangements are not adequate at SAV.  In particular, SL has not trained enough SQEPs at SAV to cope during unplanned staff absences and its plans to make a larger pool of staff available to the facility to cope with such eventualities are only at an early stage.  I have therefore assigned an inspection rating of Amber (seek improvement) against LC10.

Conclusion of Intervention

My findings were shared with and accepted by the licensee as part of normal inspection feedback.  I have raised two new Regulatory Issues as a result of this inspection, one to track SL's establishing adequate examination, inspection, maintenance and testing arrangements, and a second to track SL's establishing and implementing adequate minimum manning safety level arrangements at its facility.