Readiness Inspection on Sellafield Ltd FGMSP decanner roof replacement
- Site: Sellafield
- IR number: 19-159
- Date: January 2020
- LC numbers: 22
On 13 January 2020 ONR undertook an inspection of Sellafield Limited’s (SL’s) readiness to deploy and operate a Self Erecting Tower Crane to support the First Generation Magnox Storage Pond (FGMSP) Decanner bay roof replacement. These crane lifts are required to remove the old asbestos roof material and install the new Kalzip sheeting.
Purpose of Intervention
The purpose of the inspection was to examine the adequacy of SL’s implementation of its crane safety case and crane proposal developed under its Licence Condition (LC) 22 arrangements. The intention was to gain assurance that SL is ready to safely commence project implementation for the deployment and operation of the crane. The findings of the inspection will be used to inform the decision in response to SL’s request for ONR’s agreement to commence the lifting operations.
FGMSP was built in the 1950s for the purpose of receipt, storage and preparation of Magnox fuel for reprocessing. By 1998 operations had ceased and the facility was placed under a control and surveillance regime, although it continued to be used as a storage facility. FGMSP is an ageing facility that contains significant volumes of historical inventory including various fuels, radioactive sludge and other solid wastes. One of the activities identified to improve the integrity of FGMSP is to replace the decanner bay roof. This will provide improved weather protection for the bays, as well as routing rainwater away from the pond.
Interventions Carried Out by ONR
Licence Condition 22 requires the licensee to make and implement arrangements to control any modification or experiment carried out on any part of existing plant or process which may affect safety. This inspection focused on arrangements to prepare the plant, processes and people, and to assess the licensee’s readiness to safely commence the deployment and operation of the crane in accordance with the safety case.
Prior to the inspection I obtained a copy of the Plant Modification Proposal, associated safety case documentation and the Crane Proposal. I used these to inform my preparation and define my sampling strategy. I also obtained the licensee’s arrangements for controlling plant modifications and crane proposals. During the inspection I sought assurance from SL’s own internal governance process and confirmed that the licensee has followed this. The inspection comprised desktop-based discussions and evidence review and a visit to the crane compound to inspect and observe the crane.
The inspection was undertaken against LC 22 in accordance with ONR guidance Technical Inspection Guide (TIG) NS-INSP-GD-022, LC22: Modification or experiment on existing plant, Revision 4, January 2018. I also considered the requirements of the Management of Health and Safety at Work Regulations 1999 (MHSWR) and the Lifting Operations and Lifting Equipment Regulations 1998 (LOLER) during my inspection.
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
During the inspection I examined evidence of the licensee’s compliance with its arrangements for the control of modifications to existing plant, including safety cases to justify the proposals. I also inspected correct implementation of the construction crane arrangements and lift planning in accordance with LOLER . On the basis of my inspection, I am satisfied that the licensee has adequately implemented its arrangements to ensure sufficient control for the safe deployment and operation of the crane.
With respect to ONR’s TIG NS-INSP-GD-022, SL demonstrated that:
- The modification is being managed under the control of the First Generation Magnox Storage Pond sub-programme and is in accordance with the established site arrangements. This was evidenced by adequate close out of INSA recommendations and evidence of submission to the construction crane safety committee, Management Safety Committee.
- I noted that representatives of the different teams (SL, TDA and Mammoet) had a good understanding of the plant safety case, crane proposal and the method statements. I further noted that the Sellafield Internal Regulator was undertaking a thorough and robust assurance review of the project prior to granting internal permission.
- The project team demonstrated adequate recognition and understanding of the operating limits and conditions, including wind speed requirements and their incorporation into operating instructions. This was evidenced by review of the Crane Proposal and confirming that the limits and conditions in the interest of safety have been adequately captured by the proposal.
- SL has calculated the wind loading for specific loads . This was evidenced within the crane proposal, which had set allowable speeds below the site limit for each material lift, these had been set using formula in accordance with both the Relevant Standards (EN13000) and the Leibherr manuals, and therefore meet relevant good practice for crane safety. Adequate awareness of these limits was confirmed through discussion with the lift appointed person and crane operator. However, SL and Mammoet have agreed to provide further clarification that the limits for wind speeds during basket lifts adequately considers potential load swing with an operator nearby . This has no impact on nuclear safety, and the licensee’s Internal Regulator has agreed to provide confirmation to ONR that this is closed before the first lift.
- The project team demonstrated an adequate understanding of the command and control arrangements. This was evidenced by interviewing the TDA Project Manager, the lift contractor Appointed Person, the crane operator and crane supervisor. Each was able to articulate the roles and responsibilities, and demonstrated that they understood the safety case requirements and supervisory and control arrangements necessary for safe operation of the crane.
- The project has implemented adequate controls to ensure that all activities are carried out in accordance with the crane proposal and lifting plan. Key compliance assurance documents include: The compliance sheet; Method statement; Quality Plan and Risk assessment . We have assessed this suite of compliance documents when ONR previously assessed the construction crane safety assessment methodology and were satisfied this is an effective system to demonstrate compliance. It was evident on this proposal that SL has followed these arrangements and so we were satisfied
- Evidence was provided of adequate provision for maintenance of equipment condition throughout the lifting campaign. This was evidenced through discussion with the TDA Project Manager and the contractors Appointed Person. ONR is satisfied through this sampling that SL’s arrangements provide for adequate examination and testing of lifting equipment before use. In addition, SL’s Nuclear Inspection and Oversight team will conduct their own internal readiness review, which will include witness of the test lifts before the crane is brought to site and again when the crane is in position.
- The project demonstrated adequate controls for personnel qualification and experience, by ensuring that all lift personnel have a defined minimum level of formal qualification, in addition to which, they must complete a series of additional safety qualifications, Sellafield Ltd. courses and have completed the plant induction.
- The licensee demonstrated adequate control of Technical Queries and issues through the design process on the project, with only a small number having been raised, and none remaining outstanding.
During the inspection, the following observations were made:
- From the evidence sampled, I am satisfied that SL has followed its processes under LC22 in respect to safety assessment and implementation of its safety case and operational arrangements for construction cranes on the FGMSP, and that these will ensure adequate safety controls for the deployment and operation of the crane.
- The justification for the proposed wind speed limits requires further clarification to confirm they are suitable to ensure an operator remains safe near to a suspended load. SL and the Mammoet Appointed Person agreed to provide confirmation on this.
- Sellafield Ltd. Nuclear Inspection and Oversight function have initiated a full High Hazard Activity Readiness Review prior to bringing the crane to site. This will include reviewing the completed proposal, detailed procedures, interviewing the crane personnel and witnessing the lift test.
Conclusion of Intervention
I judged that the LC22 arrangements as implemented by SL related to the crane safety case to be adequate.
Some minor points of clarification were raised by ONR during the inspection and the SL personnel took an action to follow these up as part of the internal regulators Readiness Review and to provide the necessary clarification to ONR before the first lifts.