- Site: Sellafield
- IR number: 19-163
- Date: January 2020
- LC numbers: 15
Executive summary
Purpose of Intervention
The Office for Nuclear Regulation (ONR) undertakes all regulatory interactions with the Sellafield Site Licensee (Sellafield Limited, SL) against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. The strategy requires inspections to be performed against Licence Condition 15 relating to Periodic Safety Reviews (PSR). LC15 requires the licensee to make and implement adequate arrangements for the periodic and systematic review and reassessment of safety cases.
The purpose of this intervention was for ONR to assess the adequacy of the Infrastructure Utilities Pipebridges PSR and to ensure that SL is taking the necessary steps to continue to operate and maintain the plant in a manner that ensures that the plant risks are as low as reasonably practicable (ALARP).
The three broad objectives of this intervention were to:
- Gain confidence that SL has undertaken an adequate PSR, which takes into account lessons learnt and future foreseeable challenges.
- Gain confidence that the extant facility arrangements and the safety case are suitable and sufficient, and mitigate shortfalls awaiting improvements.
- Establish if SL has credible resolution plans to implement improvements identified by the PSR.
The inspection also provided an opportunity for ONR to gather information on the pipebridges and the contribution that the plant makes to ONR’s strategic priority at Sellafield of high hazard risk reduction.
Interventions Carried Out by ONR
On 29-30 January 2020, ONR carried out a one and a half day inspection of Licence Condition (LC) 15 compliance relating to the pipebridges. The ONR inspection team was assembled following a review of the PSR by the ONR Project inspector and consisted of a Mechanical Engineering, Civil Engineering Safety inspectors and a PSR Project inspector.
The intervention involved:
- Sampling the process and technical aspects of the application of SL PSR arrangements and associated documents.
- Discussions with appropriate members of SL staff with reference to the identified lines of inquiry.
- An inspection of pipebridges and associated structures accompanied by the Safety Case Manager, the Engineering Manager, two System Engineers and SL’s internal regulator.
The following ONR guidance was utilised as part of the inspection:
- NS-INSP-GD-015, Revision 3, Periodic Review.
- NS-TAST-GD-050, Revision 7, Periodic Safety Reviews (PSR).
- ONR Safety Assessment Principles (SAP), 2014.
Explanation of Judgement if Safety System Not Judged to be Adequate
This was not a system based inspection; therefore no judgement has been made on the adequacy of the implementation of any specific part of the safety case.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
Based upon sampling of submitted documents, discussions with SL staff and the plant inspection, ONR considers that SL has undertaken an adequate PSR of the pipebridges. The inspection did not reveal any matters of concern that had not already been identified by SL as part of its own review or were already being progressed as part of its routine business. Closure of the shortfalls identified by SL will be monitored by the ONR PSR inspector as part of routine regulatory interventions.
ONR considers that:
- SL has undertaken an adequate PSR, which has taken into account lessons learned and foreseeable future challenges.
- Arrangements to address the actions identified during the PSR are adequate.
During the inspection, ONR identified a minor shortfall in relation to a steam leak not directly related to LC15 compliance but, nevertheless, considered to be at the level requiring regulatory attention. This has been discussed with plant personnel and logged as a level 4 regulatory issue.
Conclusion of Intervention
Based on the evidence sampled during the inspection, ONR considers that SL has effectively implemented its arrangements for compliance with LC15. ONR therefore judges that an inspection rating of Green (no formal action) is appropriate for compliance against LC15 (periodic review).