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 Sub Division. In accordance with that strategy, an Inspection was carried out on the First Generation Magnox Storage Ponds (FGMSP), as planned, on 22-23rd October 2019.
The purpose of this inspection was for ONR to examine whether the licensee’s lifting operations complied with relevant Licence Conditions (LCs) and Relevant Statutory Provisions (RSPs). The following LCs and RSPs were considered:
LC10 requires SL to make and implement adequate arrangements for suitable training for all those on site who have responsibility for any operations which may affect safety.
LC23 requires SL to produce an adequate safety case to demonstrate the safety of its operations, and to identify the conditions and limits necessary in the interests of safety.
LC24 requires SL to ensure that all operations which may affect safety are carried out in accordance with written instructions.
LC27 requires SL to ensure that a plant is not operated, inspected, maintained or tested unless suitable safety mechanisms, devices and circuits are properly connected and in good working order.
LC28 requires SL to make and implement adequate arrangements for the regular and systematic examination, inspection, maintenance and testing of all plant which may affect safety.
The intervention also examined compliance with relevant statutory provisions made under the Health and safety at Work etc. Act 1974 (HSWA). In particular this focused on examining compliance with the Lifting Operations and Lifting Equipment Regulations 1998 (LOLER) however other related RSPs were also discussed.
Based upon the areas sampled I judge that the safety case requirements for FGMSP Lifting arrangements have been adequately implemented.
For LC10; I sampled the training of a crane operator and two senior roles within the facility. I judged that the training required by the role profiles had been completed and that all training was ‘in ticket’. I therefore judge that an inspection rating of Green (no formal action required) is merited.
For LC23; I was satisfied that the safety case clearly identifies the fault sequences associated with the 60te crane and that there is a clear line of sight between these and the relevant clearance certificate and operator instructions. I advised that more detailed consideration to those elements of the lift below the lifting hook could be considered to ensure that risks are ALARP. I therefore judge that an inspection rating of Green (no formal action required) is merited.
For LC24; I reviewed two instructions concerning lifting and one instruction concerning emergency egress from a crane. I noted that not all of the elements of a Lifting Plan (as required by LOLER) were evident in an operating instruction. I judged this to be a minor shortfall and raised one Level 4 regulatory issue to resolve it. On balance I was satisfied that the associated operating instructions were adequate to ensure compliance with the limits and conditions identified in the safety case and the Operating rules. I therefore judge that the required standard is met and an inspection rating of Green (no formal action) is appropriate.
For LC27; I was satisfied that the appropriate Safety Mechanisms (SM), Safety Related Equipment (SRE) and Safety Features (SF) had been identified within the safety case and had been correctly designated. During the plant visit I was not able to visually inspect the safety mechanisms as the crane was being deployed for a nuclear lift and I did not wish to hamper operations nor uptake an unnecessary dose. I will not, therefore, rate this LC.
For LC28; I sought to review the basis for maintenance of the 60te crane but no current basis existed. I then reviewed testing done on a Safety Mechanism and, whilst one work order was adequate another one had used an obsolete template and failed to rectify an identified issue. In isolation I judged these to be minor shortfalls and raised three regulatory Level 4 issues to resolve them. In addition I reviewed the use of lifting bags and noted that it was unclear if they were being used in accordance with the manufacturer’s instructions. I raised a Level 4 regulatory issue to review this. I also reviewed a number of Thorough Examination records and discovered that many defects, which required attention, had not been repaired. I raised a Level 3 regulatory issue to review and revise procedures concerning what to do with advice given via the Thorough Examination and also a Level 4 regulatory issue to action the extant advice. From the EIMT records sampled I was not satisfied that the required standard has been met and an inspection rating of Amber (seek improvement) is appropriate.
I carried out an inspection against the requirements of the Lifting Operations and Lifting Equipment Regulations 1998 (LOLER) and to a lesser extent the Provision and Use of Work Equipment Regulations 1998, the Management of Health and Safety at Work Regulations 1999 and the Work at Height Regulations 2005. I was satisfied that the licensee was largely complying with these RSPs. I judged that there were some areas where shortfalls where improvement is required. In particular there was a systematic failure to meet compliance arrangements concerning the close out of thorough examination reports as detailed in paragraph 14.
The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.
From the evidence gathered during this intervention, I do not consider there to be any matters that have the potential to impact significantly on nuclear safety. I judge that LCs 10, 23 and 24 are being adequately complied with however I judge that LC28 requires some improvement.
I have raised five Level 4 and one Level 3 Regulatory Issues in relation to LC28 (Examination, Inspection, Maintenance and Testing) and one Level 4 Regulatory in relation to LC24 (Operating Instructions).