Office for Nuclear Regulation

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Inactive Tank Farm (ITF) - LC28 Compliance Inspection

Executive summary

Purpose of intervention

The Office for Nuclear Regulation (ONR) regulates the Sellafield site licensee (Sellafield Ltd, SL) against a strategy set by the ONR Sellafield Programme.  That strategy underpins the extant 2014/2015 regulatory inspection plan for the Waste and Effluent Disposition (WEDD) and Infrastructure Directorates, which identifies that Licence Condition 28 will be inspected in November 2014.

I completed an LC28 compliance inspection of the Inactive Tank Farm (ITF), a facility within the Utilities Operating Unit (OU) of the Infrastructure Directorate.  I undertook this intervention at the infrastructure site offices on the Sellafield site in West Cumbria.

The purpose of this intervention was to inspect SL’s progress against ONR Regulatory Issue (1806) through a review of planned improvements in asset care and maintenance at the facility. ONR’s Regulatory Issue derives from an inspection conducted jointly with HSE and Environment Agency (EA) regulators in 2013 which raised concerns over asset care and safety case review at the ITF.

Interventions Carried Out by ONR

Licence Condition 28, amongst other duties, requires SL to make and implement adequate arrangements for the regular and systematic examination, inspection, maintenance and testing of all plant that may affect safety.

I completed an on-site, office-based inspection, which lasted half a working day.  My inspection was undertaken in accordance with the following ONR processes and supporting inspection guidance:

  1. NS-INSP-GD-028, Revision 3, May 2013.  LC 26 – Examination, Inspection, Maintenance and Testing (EMIT)
  2. Planning and Conducting Interventions.
  3. Record/Communicate Outcome of Intervention and Enforcement Decision

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A.  This was not a Safety System inspection.

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

Progress against the licensee’s own programme of improvements has, on the whole, been completed within expected timescales, although a number of key tasks have been delayed by wider site supply chain and operational issues, and have thus been completed after their initial planned dates.

The key area of improvement with an immediate positive impact on safety was the replacement of all five caustic tanks within the ITF; four of the five have been replaced, and the fifth has been taken out of service prior to replacement early in 2015.

The licensee has progressed a thorough programme of asset condition assessment at the ITF, although it has yet to be completed.  Completion of this programme is due within the next three months and will, in my opinion, provide valuable information to the facility owner in prioritising and planning future asset care strategies.

I have reviewed and updated ONR Regulatory Issue 1806 in light of this inspection and, as part of a follow up inspection in 2015, will track completion of the remaining commitments made by the licensee.

Conclusion of Intervention

The evidence presented at this inspection was sufficient to demonstrate to me that SL has made good progress in improving the asset condition and safety related performance of the ITF facility.  Given that my observations at this inspection were minor, I consider that an IIS rating of 3 (adequate) is justified.