Executive summary
Date(s) of inspection:
March 2025
Aim of inspection
To gain evidence to judge if Sellafield Ltd. is compliant with the Regulatory Reform (Fire Safety) Order 2005 on Pile Fuel Storage Silo (PFCS) at the Sellafield site. The inspection will be informed by compliance with Licence Conditions (LC) 10, 23, 24,27 and 28 in relation to nuclear fire safety.
Subject(s) of inspection
- Fire (Life Safety) Compliance Inspection - Rating: GREEN
- LC10 - Training - Rating: GREEN
- LC23 - Operating rules - Rating: GREEN
- LC24 - Operating instructions - Rating: GREEN
- LC27 - Safety mechanisms, devices and circuits - Rating: GREEN
- LC28 - Examination, inspection, maintenance and testing - Rating: GREEN
Key findings, inspector's opinions and reasons for judgement made
This planned inspection of the Pile Fuel Cladding Silo (PFCS) facility forms part of the 2024/25 internal hazards and fire safety inspection programme at Sellafield, following the theme of cross-purpose nuclear and life fire inspections.
PFCS currently stores 1650 Tonnes of waste in compartmented silos which contain Uranium and Sodium deposits. These silos are inerted by Argon to mitigate the risk of fire which had previously been determined as intolerable following fire risk modelling in the 1990's. PFCS has recently commenced early retrievals and aims to move to full retrieval, using lessons learned from the initial / early retrievals.
Ahead of the inspection Sellafield Ltd. provided information requested by ONR and this informed the sampling strategy employed at the inspection. During the inspection ONR site and specialist inspectors, reviewed documents, interrogated maintenance and training records on Sellafield systems, spoke with leaders and operators and conducted a walkdown of the facility.
In terms of the license conditions and legislation within the scope of this inspection, the following judgements were reached.
LC10 Training.We found the training policy to show the licensees commitment to developing and maintaining the competency of staff. Training requirements sampled were generally understood and being adhered to, and SQEP/ASQEP requirements were met. As a result we judge it appropriate to rate LC10 GREEN.
LC23 Operating Rules and LC24 Operating Instructions. We found the derivation of operating rules to be clear, operating instructions to be relevant and well understood by personnel and the relevant compliance monitoring arrangements for our sample to be adequate. As a result, we judge it appropriate to rate LC23 and LC4 GREEN.
LC27 Safety Mechanisms, Devices and Circuits and LC28 EMIT.We found the licensee to be adequately reviewing the system health and long term availability of the systems we sampled, with evidence of recent and upcoming fire alarm improvements a good example of this management. We found that maintenance was generally completed in line with the licensee’s arrangements, with some recent issues relating to the firefighting modules. We gave advice relating to better monitoring this system via existing dashboards and ensuring compliance with applicable legislation. Overall we found the implementation of the relevant arrangements within our sample to be adequate and judge it appropriate to rate both of these License Conditions GREEN.
Regulatory Reform Fire Safety Order 2005.Pre requested and supplied documentation enabled lines of enquiry to be established and a targeted approach to substantiate claims and compliance with RR(FS)O. Where matters have relationships with other activities / LC's this was examined by the relevant inspector(s) but is not duplicated in numerous areas of this document.
Arrangements for Compliance with the Regulatory Reform (Fire Safety) Order 2005
Generally it was found that the duty holder is in compliance with most legislative requirements placed by the RR(FS)O. The walk through showed a managed and controlled workplace with limited exceptions:
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Fire Risk Assessment: Some wording around occupation and Firefighting Equipment (FFE) testing appeared contradictory, however clarification was given on both areas and neither would give rise to the FRA not being considered suitable and sufficient.
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150Kg Dry Powder Fire Fighting Equipment – Vessel 3: This had recently been taken out of service due to missing periodic testing and maintenance, we gave advice on maintenance requirements in PSSR and RR(FS)O.
Positive elements were also found including:
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The Building manager placed one external staircase out of use during hours of darkness due to emergency lighting defects.
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The use of pictorial guidance fixed near to fire resisting doors as an aide memoir to staff carrying out routine checks
The PFCS facility was rated GREEN for compliance with the Regulatory Reform (Fire Safety) Order 2005.
Conclusion
LC10.We found the training policy to show the licensees commitment to developing and maintaining the competency of staff. Training requirements sampled were generally understood and being adhered to, and SQEP/ASQEP requirements were met. As a result we judge it appropriate to rate LC10 GREEN.
LC23 and LC24.We found the derivation of operating rules to be clear, operating instructions to be relevant and well understood by personnel and the relevant compliance monitoring arrangements for our sample to be adequate. As a result, we judge it appropriate to rate LC23 and LC4 GREEN.
LC27 and LC28.We found the licensee to be adequately reviewing the system health and long term availability of the systems we sampled, with evidence of recent and upcoming fire alarm improvements a good example of this management. We found that maintenance was generally completed in line with the licensee’s arrangements, with some recent issues relating to the firefighting modules. We gave advice relating to better monitoring this system via existing dashboards and ensuring compliance with applicable legislation. Overall we found the implementation of the relevant arrangements within our sample to be adequate and judge it appropriate to rate both of these License Conditions GREEN.
Regulatory Reform (Fire Safety) Order 2005.We found that the duty holder has adequate arrangements to enable compliance with the requirements imposed by the RR(FS)O and we found that documented processes, systems of work and control measures were in place during this inspection of PFCS.
We rated PFCS GREEN for compliance with the Regulatory Reform (Fire Safety) Order 2005.