Executive summary
Date(s) of inspection:
- January 2024
Aim of inspection
In accordance with the Office for Nuclear Regulation’s (ONR’s) Sellafield Strategy, each year ONR performs a series of planned inspections to seek assurance of compliance against selected licence conditions, targeted at those facilities with significant importance to nuclear safety. One such inspection was undertaken at Special Nuclear Materials North (SNM (N)) facilities within the Sellafield site in West Cumbria to sample evidence of implementation of Sellafield Limited’s arrangements for compliance with Licence Conditions (LCs) 10 (Training), 23 (Operating rules), 27 (Safety mechanism, devices and circuits) and 28 (Examination, inspection, maintenance and testing), specifically in relation to nuclear fire safety, and with the Regulatory Reform (Fire Safety) Order 2005, in order to inform a regulatory judgement regarding the licensee’s compliance with its legal duties under the nuclear site licence and Regulatory Reform (Fire Safety) Order 2005.
Subject(s) of inspection
- LC10 – Training – Rating: Green
- LC23 – Operating rules – Rating: Green
- LC27 – Safety mechanisms, devices and circuits – Rating: Green
- LC28 – Examination, inspection, maintenance and testing – Rating: Amber
- Regulatory Reform (Fire Safety) Order 2005 – Rating: Green
Key findings, inspector’s opinions and reasons for judgement made
The inspection was undertaken on 10 and 11 January 2024. The inspection team comprised of the SNM site inspector, two internal hazards specialist inspectors and one internal hazards and life fire specialist inspector. The inspection targeted compliance against Licence Conditions (LCs) 10 (Training), 23 (Operating rules), 27 (Safety mechanism, devices and circuits) and 28 (Examination, inspection, maintenance and testing), specifically in relation to nuclear fire safety, and compliance with the Regulatory Reform (Fire Safety) Order 2005.
The inspection involved a planning phase and a site visit, which included facilities walkdown, discussions with relevant Sellafield Limited personnel, review of records, and sampling of information contained within electronic databases and other documentation.
Based on the evidence sampled, we concluded the following:
No significant matters were identified that required immediate regulatory attention.
For LC10 we identified no shortfalls that require regulatory attention.
For LC23 whilst some minor anomalies identified between documents, we were satisfied that structures, systems and components (SSCs) delivering the nuclear fire safety functions had been identified in the safety case.
For LC27 Sellafield Limited provided assurance that all SSCs listed in the Engineering Schedule have been installed on the plant and known shortfalls have been captured in a fire actions list. We raised a Level 4 Regulatory Issue to confirm alignment of installed key SSCs with all documentation, and to develop a prioritised credible action plan for addressing the known fire compartmentation issues at SNM (N).
For LC28 whilst some maintenance records were made available on civil structures and doors, we identified gaps in terms of plant maintenance schedules availability, and maintenance records for those key SSCs listed in the Engineering Schedule. We also found discrepancies between the inspection periodicity listed in the Engineering Schedule and the maintenance records provided. Sellafield Limited recognised the gaps identified, and raised a condition report with associated actions and proposed timescales. We therefore, we will seek improvement in this area and we raised a Level 3 Regulatory Issue.
For the Regulatory Reform (Fire Safety) Order 2005, notwithstanding the shortfalls identified in the LC27 and 28 above, we identified no shortfalls that require regulatory attention; the risk assessments, escape means and fire drills sampled are adequate.
Conclusion
On the basis of the evidence sampled at the time of the inspection, we found that Sellafield Limited is largely compliant with the licensee’s corporate arrangements for LC10, 23, 27, and the Regulatory Reform Fire Safety Order 2005 at SNM (N).
We also found that the licensee did not adequately implement the licensee’s corporate arrangement, made for compliance with the Nuclear Site Licence, for LC28 and specifically with the requirements of LC28 (1), (4) and (6).
Taking all of the above into account, and noting the ONR guidance on inspection ratings, we judge that an inspection rating of Green (i.e. no formal action) for Licence Condition LC10, 23, 27 and Regulatory Reform Fire Safety Order 2005, is appropriate. One L4 Regulatory Issue will be raised to track progress with the shortfall identified in relation to LC27.
We also judge that an inspection rating of Amber for LC28 is appropriate and we will seek improvement in this area via a L3 Regulatory Issue.