Office for Nuclear Regulation

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Planned Licence Condition 22 compliance inspection at Sellafield

Executive summary

Purpose of intervention

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 Sellafield, Decommissioning, Fuel and Waste (SDFW) Programme.

A licence condition (LC) compliance inspection in the Decommissioning Operating Unit (OU) was carried out, as planned, in December 2016 at the Pile Fuel Cladding Silo (PFCS) facility. This inspection aligns with the Sellafield Compliance, Intelligence and Enforcement (SCIE) sub-programme inspection plan PP3 and also delivers one of the objectives of the Sellafield Project Delivery sub-programme task sheet ONR-SEL-TS-16-005 (TRIM 2016/33182).

The purpose of this intervention was for ONR to determine the adequacy of implementation of the licensee's formal arrangements for compliance with LC 22 (modifications or experiment on existing plant). The inspection considered the local approach taken at PFCS to comply with the site-wide LC22 arrangements and sampled a number of different plant modifications/experiments from the past three years of operation. Additional focus was applied to the implementation of the deflector plate removal (DPR) work currently underway at PFCS.

Interventions Carried Out by ONR

LC 22 requires that the licensee implements adequate arrangements for the control of modifications or experiments carried out on any plant or processes which may affect safety. On 13 December 2016 I carried out a planned, one-day, on-site LC 22 compliance inspection within the Decommissioning OU at the PFCS facility. The inspection comprised discussions with SL and James Fisher Nuclear (JFN) staff and reviews of relevant plant records and other documentation. In carrying out this inspection, I followed the ONR guidance in ONR-INSP-GD-022, Revision 3, issued in December 2014.

The inspection was supported by two members of the SL Internal Regulation team comprising the PFCS Internal Regulator for Compliance and a representative of the PFCS Internal Regulator for Permissioning.

Explanation of Judgement if Safety System Not Judged to be Adequate

This was not a system based inspection, and therefore no judgement has been made of the adequacy of implementation of any part of these safety cases.

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

In general, the inspection found evidence for a good standard of implementation of the licensee's LC22 arrangements. In particular, it was noted that senior PFCS staff were closely aware of all the recent and currently-live Plant Modification Proposals (PMPs) that were sampled.

There are a number of overdue PMPs (13 permanent modifications with PMPs open for more than 3 years) that remained to be closed. The Head of Operations stated that he intended to revive the ‘PMP surgery' approach that had been used in the past to tackle the backlog. This was reported to have been successful in the past but it appears that PMP closure performance has recently been allowed to slip. The Head of Operations reported that the issue has also been raised at the PFCS Programme Board level. I note that the issue of overdue PMPs is a site-wide problem and is already the subject of ONR Regulatory Issue 2952 (level 3). I will be working with the SL Internal Regulator to monitor the PFCS commitment to reduce the number of overdue PMPs.

It was clear that there needs to be earlier and closer contact between the PFCS safety and security community in the preparation and implementation of some PMPs. This had been recognised by the facility prior to the inspection and I was told that closer engagement was already underway for the upcoming Retrievals Access Penetration (RAP) operations PMP. I have already discussed this topic with the ONR Security Inspector for PFCS following a minor security-related issue with the DPR arrangements.

The inspection team undertook a detailed examination of plant records associated with the ongoing DPR work to see if the safety precautions laid out in the DPR PMP were being properly implemented. In all but one aspect the documents reflected thorough implementation of the PMP. I did identify a shortfall where an error in the transcription of a hydrogen level measurement from the original record through to higher level plant management documentation. In this instance, this error had no safety significance and the relevant DAP and the Head of Operations were clear on the hydrogen level safe operating envelope and trend of very low hydrogen levels. This appears to be one-off mistake but I noted the potential for such errors to have safety significance in future. I will work with the SL Internal Regulator to follow this up.

Conclusion of Intervention

Based on the areas sampled, I consider that the licensee is compliant with its duties under LC 22 although some minor areas for further improvement were identified. It is my opinion that an inspection rating of GREEN (no formal action required) is appropriate.