Office for Nuclear Regulation

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Planned LC21 compliance inspection at the Sellafield Pile Fuel Cladding Silo (PFCS)

Executive summary

Purpose of Intervention

This report presents the findings of a planned intervention that was undertaken at the Sellafield nuclear licensed site on 17-18 December 2018. The purpose of this inspection was to determine Sellafield Limited’s compliance to Licence Condition 21 (Commissioning) for the Pile Fuel Cladding Silo (PFCS) facility.

The findings of this inspection will also be used to inform the ONR intervention strategy for PFCS Early Retrievals, which is in the process of inactive plant commissioning and is planned to, subject to an ONR licence instrument, enter into active commissioning later in 2019.

Interventions Carried Out by ONR

During this intervention, I carried out a compliance inspection against Licence Condition LC 21 (Commissioning) against the requirements of ONR's published inspection guidance for LC21 (NS-INSP-GD-021). The inspection was supported by the SL Nuclear Independent Oversight (NIO) Project Delivery Internal Regulator.

The inspection comprised of an examination of the PFCS Early Retrievals project commissioning strategy, quality plans, local arrangements and records. It included sampling of Sellafield Ltd (SL) documents and documentation produced by Bechtel Cavendish Nuclear Solutions (BCNS) who are under contract to SL to provide equipment and services on the PFCS ER project.

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A – this was not a systems-based inspection.

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

The inspection found evidence that PFCS had produced the high-level documents required by SL’s arrangements (including quality plans, a commissioning strategy and a plant test schedule) and that these were generally up to date and of suitable quality, although a minor area for improvement was identified in the area of version control, amendment and approval of documentation, which could be improved through stricter adherence to SL processes and through improvements to document templates.

The commissioning worksheets (or equivalent documents as used to plan and record commissioning activities) that were sampled were suitable and sufficient, noting that a number of commissioning activities have taken place to date and that a number remain to be carried out. Again, some minor improvement in version control, amendment and approval of documentation (as noted above) was identified.

Fault observations and technical queries arising from commissioning work were, based on the sample observed, being recorded and treated appropriately.

SL had generally effective oversight and surveillance of the subcontractor (BCNS) and that effective governance of commissioning activities was in place through a number of scrutiny committees. A further area for improvement was in relation to the evidence and process by which SL assured itself that activities being carried out by the subcontractor are being undertaken by demonstrably suitably qualified and experienced (SQEP) persons. There was no evidence that personnel were not SQEP, but there appeared to be weaknesses in SL’s visibility of all of the requisite evidence (e.g. professional qualification records).

Conclusion of Intervention

I judge that, on balance, an inspection rating of Green (No formal action) is warranted against Licence Condition 21; however, I have raised two ONR level 4 regulatory issues to monitor improvement against the two minor areas of weaker compliance noted above.