Office for Nuclear Regulation

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LC 12 & 26 Compliance Inspection - Combined Heat and Power at 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 2017 - March 2018), the content of which is guided by that strategy, identifies the Licence Conditions (LCs) that will be inspected over this period.

This planned inspection was undertaken to determine if SL's Fellside Combined Heat and Power facility is adequately implementing the licensee's site-wide arrangements for compliance with Licence Condition 12 (Duly authorised and other suitably qualified and experienced persons), and Licence Condition 26 (Control and supervision of operations). The Fellside Combined Heat and Power facility has an important duty role as it supplies process steam to a number of Sellafield site-wide operating facilities, including its high hazard and risk reduction work. Steam has an important safety function as it is used to transfer radioactive liquids via steam ejectors, as well as being used for heating and evaporation functions.

The overall adequacy of SL's site-wide LC 12 and 26 arrangements are considered separately in other ONR inspections.

Interventions Carried Out by ONR

Licence Condition 12 (LC12) requires the licensee to make and implement adequate arrangements to ensure that only suitable qualified and experienced persons perform any duties which may affect safety of operations on the site or any other duties assigned by or under these conditions or any arrangements required under these conditions.

Licence Condition 26 (LC26) requires the licensee to ensure that no operations are carried out which may affect safety except under the control and supervision of suitably qualified and experienced persons appointed for that purpose by the licensee.

These duties apply at the Fellside Combined Heat and Power facility even though it is managed under contract by PX Group Limited as the facility is on the licensed site and conducts functions important to safety.

My inspection, which comprised discussions with staff, examination of plant documentation, and inspection of the facility equipment, focussed on its:

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

There were no significant findings identified during my inspection, and I have not raised any associated Regulatory Issues.

The licensee demonstrated an adequate understanding of its LC12 site-wide arrangements. Overall, I consider that the licensee has adequately implemented its arrangements for compliance with LC 12 for the Combined Heat and Power facility. The licensee demonstrated a good understanding of specific legislative requirements applicable to this facility; for example: Dangerous Substances and Explosive Atmospheres Regulations (DSEAR), and Control Of Major Accident Hazards Regulations (COMAH) Regulations. However, there were also some minor areas for improvement identified, for example the licensee's training reporting management arrangements are an area for improvement as a number of aspects where found to be ambiguous.

The licensee demonstrated an adequate understanding of its LC 26 site-wide arrangements. Overall, I consider that the licensee has adequately implemented its arrangements for compliance with LC 26 for the Combined Heat and Power facility. Indeed, this implementation is good in several areas, for example the appointment of a single point of contact to control and manage communications to the Sellafield site. However, there were also some minor areas for improvement identified; for example SL in its Intelligent Customer role should seek to secure its own assurance that appointed contractors are suitably qualified and experienced.

Conclusion of Intervention

As I found no significant shortfalls, on balance, I consider an inspection rating of Green (no formal action) is merited against both LC 12 and LC 26 as a result of this inspection.

My findings were shared with and accepted by the licensee as part of normal inspection feedback. I have not raised any Regulatory Issues as a result of this inspection.