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 ONR’s 2014/2015 regulatory inspection plan for Product Management and Finishing (PMF), which identifies that Licence Conditions 22 and 28, will be inspected in January 2015. We carried out the LC 22 and 28 compliance inspections of the Product Management and Finishing (North) (PMF (N)) facilities within the Spent Fuel Directorate on the Sellafield site.
The PMF (N) facilities carry out essential reprocessing work on the site in support of the UK’s Magnox Operating Plan and so play an important role in the UK’s product management strategy. Several of the individual facilities are original first generation build and make a significant contribution to the site’s overall risk. They are also important to the delivery of the site’s hazard and risk reduction programme.
In addition to their importance to nuclear safety, the ageing and obsolescence issues posed by these older facilities make them important from a security and environmental perspective. This inspection was therefore conducted jointly with ONR nuclear security, Environment Agency (EA) and Sellafield Limited internal inspectors.
The interventions carried out by ONR were:
Licence Condition 22 requires the licensee, amongst other duties, to make and implement adequate arrangements to control modifications to its plants or processes that may affect safety. Using ONR guidance document NS-INSP-GD-22, I completed a half-day, on-site inspection of LC 22 implementation compliance centred on the PMF (N) improvement projects. The inspection focussed on the following areas:
Licence Condition 28 requires the licensee, amongst other duties, to make and implement adequate arrangements for the regular examination, inspection, maintenance and testing of all plant that may affect safety. My half day inspection against this licence condition was carried out in accordance with ONR’s inspection guidance for this Licence Condition 28, NS-INSP-GD-028 Rev 3. During the inspection I examined the implementation of the site’s arrangements for compliance with LC28 focussing on a number of the key buildings in PMF (N) and correlated these findings with my observations of the current condition of the assets and the plans for on-going care and maintenance of these assets.
Not applicable, this was not a Safety System Inspection.
All parties considered the joint regulatory approach (ONR nuclear safety, ONR nuclear security, Environment Agency, Sellafield Ltd Internal regulator) to be a very positive approach through which PMF (N) received coherent, integrated regulatory advice rather than different priorities from different regulators.
From inspection of the documentation etc. associated with the PMP process in PMF (N), it is my opinion that compliance with the requirements of LC 22 is adequate and suitable to support the requirements of the planned improvement projects.
It is also my opinion that, when considered against the requirements of LC 28, the use by the PMF (N) civil system engineers of the safety case, engineering schedule, plant maintenance schedule, Asset Specific Inspection Specification and inspection reports etc. was adequate. I identified shortfalls, however, where the required improvement or repair works were not being carried out on the plant. This was particularly prevalent where responsibility for those required tasks had been transferred from the facility’s civil system engineers out to SL’s (site) Project Team.
A visual inspection of the civil structures revealed that there are a broad range of significant defects affecting the external building envelope and aging issues associated with its civil structures, e.g. the roofs of the production facilities, which require attention.
From a limited camera-based inspection of the underground ventilation duct I could observe a significant amount water was present. I was not able to determine whether the water level was constant or subject to change.
It is my opinion that PMF (N) is implementing adequately SL’s arrangements for LC 22 compliance and that the facility’s LC 22 arrangements are adequate to support the programme of improvement projects. I have assigned an IIS rating of adequate (3).
However, it is my opinion that compliance with LC28 is below standard (IIS 4, yellow), i.e. while fundamental requirements are being met I identified some specific procedural weaknesses. Specifically, I observed failures to implement within an appropriate timescale, the maintenance tasks identified by SL’s process. A regulatory issue identifying this shortfall will be added to our Regulatory Issues database.
It is our opinion that the currently identified, discrete PMF (N) major improvement projects together with the plans to address other recognised significant safety, security and environmental matters should to be brought together into a pragmatic, risk-informed improvement programme that is based on a realistic appraisal of the remaining function and lifespan of the facilities. SL will be asked to present this programme to the joint regulators forum for consideration.
It is our opinion that the recently initiated joint regulatory approach should continue as it will enable PMF (N) to respond to coherent, joint regulatory advice, and provide increasing clarity and efficiency in determining pragmatic, risk informed improvement for these facilities.