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 the Remediation OU, part of SL’s Operating Division, is adequately implementing SL’s site-wide arrangements for compliance with Licence Condition 28 (Examination, inspection, maintenance and testing). The intervention targeted the implementation of SL’s arrangements by their tenant, National Nuclear Laboratories (NNL), within the Active Handling Facility (AHF). The inspection focussed on the instrumentation components of the red extraction ventilation system that may affect safety. The reliabilities of the red extract ventilation system and these components are important to nuclear safety in AHF. This facility is also important to supporting hazard and risk reduction activities on the site.
Licence Condition 28 (LC 28) requires the licensee to make and implement adequate arrangements for the regular and systematic examination, inspection, maintenance and testing of all plant which may affect safety.
My inspection, which comprised discussions with SL and NNL staff, examination of plant documentation, and an inspection of the AHF facility and red extract ventilation instrumentation, focussed on the following areas:
Not applicable; this was not a Safety System inspection.
NNL’s arrangements are endorsed by SL as meeting its LC28 arrangements and I consider that these arrangements for compliance with LC 28 have, in the main, been implemented within the AHF facility. There were some areas of good practice, some areas where minor improvements could reasonably be made, one minor shortfall and two significant shortfalls against identified relevant good practice, all of which were accepted by the tenant and licensee.
Overall, I consider the implementation of the arrangements for LC28 is adequate in most areas. For instance, there was good evidence in relation to recognition of the status and importance of the red extract ventilation system from an ongoing operational perspective, and also the training of the task supervisors responsible for the delivery of maintenance of the instrumentation components that may affect safety. This is, however, offset by two significant shortfalls and one minor shortfall. In particular, to correct the significant shortfalls, NNL should adequately document how they implement the required operating instruction to stop work and evacuate the AHF in the event the instrumentation indicates a total loss of the red extract ventilation; NNL should also carry out adequate proof tests and maintenance of all of the instrumentation components of the red extraction ventilation system that may affect safety. In addition, to correct the minor shortfall, NNL should improve the condition of the Amber no 4 cabinet.
For these reasons, on balance, I consider an Inspection rating of Amber (Seek improvement) is merited against LC 28 as a result of this inspection.
My findings were shared with, and accepted by NNL and SL as part of normal inspection feedback. I will raise two Level 3 and one Level 4 ONR Regulatory Issues as a result of this inspection.