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 Oxide Fuel Storage Group (OFSG), as planned, on 16-17 December 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.
LC15 requires SL to make and implement adequate arrangements for the periodic and systematic review and reassessment of safety cases.
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.
LC26 requires SL to ensure that no operations are carried out which may affect safety except under the control and supervision of suitably qualified and experienced persons.
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 OFSG Lifting arrangements have been adequately implemented.
For LC10; I sampled the training of personnel involved in the flask movement which the inspectors witnessed. These were the Duly Authorised Person, the Banksman/Slinger and an Operator. I judged that the training required for 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 LC15; The sampling of the periodic safety review for lifting equipment was reactive and un-planned. I sought to sample the ALARP argument for continued use of lifting equipment but no appropriate argument was readily available. I judged this to be a minor shortfall and raised one Level 4 regulatory issue to resolve it. As this sampling was brief and of a narrow focus I will not, therefore, rate this LC.
For LC23; I sampled a number of relevant limits/conditions within the safety case and their implementation, and also considered the broad approach taken to the nuclear safety assessment of lifting operations. Whilst I made a number of minor observations on the implementation of limits/conditions, I was satisfied that they were adequately implemented. I recognised some ambiguity in the claims made in the criticality safety case concerning uncontrolled lowering of loads and advised OFSG to seek clarity on the basis of its case. However, I was satisfied that management of lifting operations to prevent uncontrolled lowering was considered in the wider safety case and on this basis do not propose pursuing this further with the facility. This intelligence will feed into the site wide review of lifting operation assessments. On the basis of the evidence sampled, I judge that a rating of green is appropriate.
For LC24; I sampled two operating instructions concerning lifts being undertaken on the day of the inspection. I noted that improvements could be made to the risk assessment for the on-site AGR flask lift and that clarification could be given on the use of consignment notes to help identify skips for the in-cell lifts. Improvements were identified to operating instructions as a result of the inspection for which SL took immediate action are covered within the summary under ‘LOLER and other RSPs’. I therefore judge that an inspection rating of Green (no formal action required) is merited.
For LC26; I sampled the supervision and control of the facility DAP; the lifting of the on-site AGR flask; and also the supervision and control of the in-cell lifting of a skip. No issues were raised and no advice was given. I was satisfied that there was adequate supervision and control within the facility. I therefore judge that an inspection rating of Green (no formal action required) is merited.
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 due to time constraints. I will not, therefore, rate this LC.
For LC28; I sampled a number of proof test instructions, work orders and the technical basis of maintenance associated with a sample of lifting equipment safety mechanisms and safety related equipment. I noted that where a generic basis of maintenance is used then the facility did not always complete all tests. I have advised the facility to remedy this. In addition I reviewed all recent maintenance on the New Transfer Bay crane and noted that defects on the primary brake drum were being monitored, however I was not satisfied that a clear justification for continued use of this brake had been made and so I raised a L4 regulatory issue to explore this issue further. On balance I was content with the examination, inspection, maintenance and testing being undertaken within the facility (note that observations on examination, inspection, maintenance and testing are also made under the ‘LOLER and other RSPs’ paragraph). I therefore judge that an inspection rating of Green (no formal action required) is merited.
For LOLER and other Relevant Statutory Provisions; I targeted LOLER regulations 7 to 10 (marking of lifting equipment; organisation of lifting operations; thorough examination and inspection; and inspection reports and defects); and PUWER Regulation 5 (maintenance). During the plant walk down I noted several areas for improvement and offered appropriate advice to SL. I raised two regulatory issues. I noted a risk of serious personal injury (ROSPI) associated with a lift where an operator was unnecessarily close to a moving load. Due to the prompt action of SL immediately following the inspection to remedy this lifting operation in future, I have raised this as a level 4 issue to ensure that appropriate changes are formally made to the operator instructions. In addition I raised a level 4 issue regarding maintenance as I noted that observations (Cat B) made by the Competent Person during the Thorough Examination were not being acted upon in a timely manner as required by the regulations.
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, 24, 26 and 28 are being adequately complied with. I also judge that compliance against LOLER and other relevant statutory provisions is adequate.
I have raised 4 Level 4 Regulatory Issues. The issues are concerned with LC15 (Periodic Safety Review); LC28 (Examination, Inspection, Maintenance and Testing); LOLER Reg 8 (organisation of lifting operations); and PUWER Regulation 5 (maintenance).