Date(s) of inspection:
- November 2023
Aim of inspection
The intervention follows a number of events reported by the Capenhusrt Site associated with the maintenance of safety-related systems.
The aim is to gather information (evidence), at a strategic level, regarding the approach being taken to asset management across the site. This part of the intervention will not be rated. The intervention will also sample how structures, systems and components important to safety are being adequately examined, inspected, maintained and inspected, in-line with the site’s approach to asset management and their Licence Condition (LC) 28 compliance arrangements. The information gathered from this part of the intervention will be used to provide an inspection compliance rating against LC28.
Subject(s) of inspection
- COMAH – Control of Major Accident Hazards Regulations 2015 – Rating: Not rated
- LC28 – Examination, inspection, maintenance and testing – Rating: Green
Key findings, inspector’s opinions and reasons for judgement made
This was a planned joint intervention conducted over three days with the Capenhurst Site’s Internal Assurance function. Three organisations operate across the site, Urenco UK Ltd. (UUK) – the holder of the Nuclear Site Licence and two tenants, Urenco Nuclear Stewardship (UNS) and Ureco Chem. Plants (UCP). The main aims of the intervention were to:
Gather strategic level information on the site’s approach to asset management.
Inspect the dutyholder’s implementation of their arrangements for complying with Licence Condition (LC)28 – Examination, Inspection, Maintenance and Testing.
The inspection comprised discussions with UUK, UNS and UCP staff, a review of relevant processes and procedures, and a plant walkdown of a UNS facility.
For asset management, the International Organisation for Standardisation 55000 series of standards and relevant parts of ONR’s Technical Assessment Guides on Civil Engineering and Ageing and Degradation Management, were used as benchmarks to inform regulatory judgements. ONR’s Technical Inspection Guide NS-INSP-GD-028 was used to judge compliance with LC28.
The inspection found the dutyholder is taking appropriate steps to address self-identified shortfalls in compliance with some aspects of LC28. ONR was satisfied with current progress, and will continue to maintain regulatory oversight as a matter of routine.
For asset management, the inspection identified several good practices. However, as self-identified by the dutyholder; at present they largely adopt a reactive approach – especially for obsolescence. The inspection found UUK, UCP and UNS have disparate approaches to asset management; as does the Urenco Group. From a regulatory perspective, this raises some concerns regarding the ability of the site licensee and tenant organisations to adequately discharge their legal duties without undue influence from the Parent Body Organisation, and for there to be assurances that appropriately prioritised and consistent investment decisions for assets most critical to safe and secure operations, are being made. A Level 3 Regulatory Issue (RI-11817) has been raised to seek assurances these points are adequately addressed.
The inspection found the site wide fire-fighting main is in a degraded state and requires refurbishment. Some design work has been undertaken, but investment for refurbishments remains under review. A level 4 Regulatory Issue (RI-11846) has been raised to seek assurances this work is progressed in a timely manner.
The site’s approach to asset management was not rated. Applying ONR’s rating guidance in ONR-INSP-GD-064, on balance, an inspection rating of GREEN was assigned for compliance with LC28.
LC28 – Examination, Inspection, Maintenance and Inspection
The inspection revealed some areas of non-compliance with the control and supervision aspects of LC28. There have also been some missed/delayed maintenance activities in the recent past, which fall within the scope of LC28. All of these shortfalls were self-identified by the dutyholder. During the inspection they were able to demonstrate suitable corrective actions are being taken to prevent a reoccurrence of similar events. For all other aspects of LC28 inspected, no shortfalls in compliance were identified. Based on the balance of the sample selected and evidence gathered, we therefore judged UUK, UNS and UCP are compliant with the requirements of LC28. Applying ONR’s inspection ratings guide in ONR-INSP-GD-064, an overall rating of GREEN is most appropriate.
The inspection found UUK, UCP and UNS have disparate approaches to asset management; as does the Urenco Group. Whilst there was some evidence of alignment with good practice, the site does not have fully developed asset management plans. The dutyholders are moving in the right direction; however, from a regulatory perspective, there are some concerns regarding the ability of the site licensee and tenant organisations to adequately discharge their legal duties, without undue influence from the Parent Body Organisation. There needs to be assurances that appropriately prioritised and consistent investment decisions for assets most critical to safe and secure operations are being made by the site. The site’s overall approach to asset management was not rated. However, considering the findings of the intervention, we considered it necessary and proportionate to raise a Level 3 Regulatory Issue (RI-11817) on the topic of asset management.
The inspection identified some potential shortfalls regarding the current performance and reliability of the site-wide fire fighting main, which might impact on the dutyholder’s ability to adequately respond to an on-site emergency. We considered it necessary and proportionate to raise a Level 4 Regulatory Issue (RI-11846), requesting the site to demonstrate the risk associated with the fire main condition is understood, being appropriately managed, and will be addressed in a timely and prioritised manner.