- Site: Sellafield
- IR number: 22-033
- Date: June 2022
- LC numbers: 23, 27, 28, 34
Purpose of Intervention
The Office for Nuclear Regulation (ONR) undertakes all regulatory interactions with the Sellafield site licensee (Sellafield Limited) against a strategy defined by the ONR Sellafield Subdivision. In accordance with this strategy, a planned Licence Condition (LC) compliance inspection was carried out of the Laboratory 54/54A within B229.
The purpose of this inspection was to confirm that Sellafield Limited is adequately implementing the licensee’s site-wide arrangements for compliance with LC23 (Operating rules), LC27 (Safety mechanisms, devices and circuits), LC28 (Examination, inspection, maintenance and testing) and LC 34 (Leakage and escape of radioactive material and radioactive waste) at Laboratory 54/54A within the B229 facility, which is owned and managed by Analytical Services.
Interventions Carried Out by ONR
The inspection was a planned LC23, LC27, LC28 and LC34 at Laboratory 54/ 54A within the B229 facility and was undertaken on 15 and 16 June 2022 by the ONR Site Inspector for Remediation Value Stream supported by a civil engineering specialist inspector. A representative of Sellafield Limited Nuclear Intelligence and Independent Oversight (NI&IO) function also participated. The ONR inspectors were joined by an inspector from the Environment Agency on 16 June.
LC23 (1) requires the licensee in respect of any operation that may affect safety, to produce an adequate safety case to demonstrate the safety of that operation and to identify the condition and limits necessary in the interest of safety. Such condition and limits shall hereinafter be referred to as operating rules.
LC27 requires the licensee to ensure that a plant is not operated, inspected, maintained or tested unless suitable and sufficient safety mechanisms, devices and circuits are properly connected and in good working order.
LC28 (1) requires the licensee to make and implement adequate arrangements for the regular and systematic examination, inspection, maintenance and testing of all plant which may affect safety.
LC28 (6) requires the licensee to ensure in the interests of safety that every examination, inspection, maintenance and test of a plant or any part thereof is carried out:
- by suitably qualified and experienced persons;
- in accordance with schemes laid down in writing;
- within the intervals specified in the plant maintenance schedule; and
- under the control and supervision of a suitably qualified and experienced person appointed by the licensee for that purpose.
LC 28 (9) requires the licensee to ensure that a full and accurate report of every examination, inspection, maintenance or test of any part of a plant indicating the date thereof and signed by the suitably qualified and experienced person appointed by the licensee to control and supervise such examination, inspection, maintenance or test is made to the licensee forthwith upon completion of the said examination, inspection, maintenance or test.
LC 34 (1) requires the licensee to ensure, so far as is reasonably practicable, that radioactive material and radioactive waste on the site is at all times adequately controlled or contained so that it cannot leak or otherwise escape from such control or containment.
LC 34 (2) requires the licensee to ensure, so far as is reasonably practicable, that no such leak or escape of radioactive material or radioactive waste can occur without being detected, and that any such leak or escape is then notified, recorded, investigated and reported in accordance with arrangements made under Condition 7.
As part of the preparation for the delivery of this intervention, the following formal ONR guidance documentation was used:
- ONR-INSP-GD-059 Revision 8 Guidance for Intervention Planning and Reporting;
- ONR-INSP-GD-064 Revision 5 General Inspection Guide;
- NS-INSP-GD-023 Revision 5 LC23 – Operating Rules;
- NS-INSP-GD-027 Revision 6 LC27 – Safety Mechanisms, Devices and Circuits;
- NS-INSP-GD-028 Revision 8 LC28 – Examination, Inspection, Maintenance and Testing; and
- NS-INSP-GD-034 Revision 6 LC34 – Leakage and Escape of Radioactive Material and Radioactive Waste.
The inspection comprised discussions with Sellafield Limited personnel, a review of a targeted sample of Sellafield Limited documentation and a plant visit.
The inspection focused on the following areas:
- In respect to LC23: the current safety case, the clearance certificate, the Safety Case Implementation Plan (SCIP) and compliance records documents.
- In respect to LC27: the current safety case, the clearance certificate and the derivation of key Safety Mechanisms, Devices and Circuits associated with Laboratory 54/54A civil structures, containment and associated pipework.
- In respect to LC28: Laboratory 54/54A civil structures, containment, associated pipework and associated alarms.
- In respect to LC34: the C3 containment, the activity in air monitors in Laboratory 54/54A, active ventilation system and associated alarms.
The scope and focus of the inspection took into account of intelligence gained from various ONR interventions.
Explanation of Judgement if Safety System Not Judged to be Adequate
This was not a system-based inspection, and therefore no judgement has been made of the adequacy of implementation of any part of the safety case.
Key Findings, Inspector’s Opinions and Reasons for Judgements Made
During the LC23, LC27, LC28 and LC34 compliance inspection, we sampled evidence associated with Sellafield Limited’s compliance with its corporate arrangements and concluded the following.
In relation to LC23, Laboratory 54/54A has a combined remediation enabling, surveillance and maintenance operations safety case and a valid clearance certificate. The safety case is in the process of implementation by the Safety Case Implementation Plan (SCIP), however, with no confirmed date of completion. The inspection identified that several documents require a review and update to reflect the current safety case and clearance certificate. This also includes correct labelling of plant equipment in the Laboratory 54/54A as Safety Mechanisms, Safety Related Equipment and Safety Features and removal of equipment that are not used for operational reasons. We judged it to be proportionate to raise a new Level 4 Regulatory Issue (10866) to track to completion Sellafield Limited’s full implementation of the SCIP.
Our sample of compliance records identified areas of reduction in the frequency of operator rounds from daily to weekly and a gap in the current management arrangements and coordination of the operations between B229 and the Remediation Value Stream, including the control and supervision of operations undertaken by the Remediation Value Stream in Laboratory 54/54A. We judged it proportionate to raise a new Level 4 Regulatory Issue (10867) to track this shortfall to completion. Sellafield Limited recognised this gap and proactively set up a meeting on 28 June to discuss this shortfall with all relevant stakeholders.
In relation to LC27, despite some anomalies in the markings of plant and equipment, which were associated with the full implementation of the SCIP, we were satisfied that Safety Mechanisms, Devices and Circuits (SMDC) had been identified in the safety case, could be located on plant and were properly connected and in good working order or good condition.
In relation to LC28 we sampled the maintenance and inspection records for the C3 containment, gloveboxes, primary and secondary HEPA filters and alpha in air monitors and concluded that examination, inspection, maintenance and testing (EIMT) is being undertaken in an appropriate and timely manner. Based on the training evidence sampled we were satisfied that the operative and supervisor were suitably qualified and experienced for the task.
In relation to LC34 we sampled the maintenance records for the HEPA filter flow tests and activity in air monitors functionality checks and we were satisfied that these items were being adequately maintained. We were satisfied that the required improvements to C3 containment had been made and that the containment is capable of preventing a release of gross contamination in the event of glovebox failure. During our site walkdown we confirmed that the visible activity in air monitors were functioning.
Conclusion of Intervention
On the basis of the evidence sampled at the time of the inspection, and noting the ONR guidance on inspection ratings, we consider that an inspection rating of Green (no formal action) is merited for Sellafield Limited implementation of its LC23, LC27, LC28 and LC34 corporate arrangements in Laboratory 54/54A within B229.
Two Level 4 (i.e.; lowest level) Regulatory Issues have been raised to manage the implementation of the identified areas for improvement.