- Site: Sellafield
- IR number: 19-192
- Date: March 2020
- LC numbers: 7, 10, 15, 23, 24, 26, 27, 28
Executive summary
Purpose of Intervention
The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Sellafield site licensee (Sellafield Limited, SL) against a strategy defined by the ONR Sellafield Sub Division. In accordance with that strategy, an inspection was carried out on the High Level Waste Plant (HLWP), as planned, on 3-5 March 2020.
Interventions Carried Out by ONR
The purpose of this inspection was for ONR to examine whether the licensee’s lifting operations complied with relevant Licence Conditions (LCs) and Relevant Statutory Provisions (RSPs). The following LCs and RSPs were considered:
- LC7 requires SL to make and implement adequate arrangements for the notification, recording, investigation and reporting of incidents on the site.
- LC10 requires SL to make and implement adequate arrangements for suitable training for all those on site who have responsibility for any operations which may affect safety.
- LC15 requires SL to make and implement adequate arrangements for the periodic and systematic review and reassessment of safety cases.
- LC23 requires SL to produce an adequate safety case to demonstrate the safety of its operations, and to identify the conditions and limits necessary in the interests of safety.
- LC24 requires SL to ensure that all operations which may affect safety are carried out in accordance with written instructions.
- LC26 requires SL to ensure that no operations are carried out which may affect safety except under the control and supervision of suitably qualified and experienced persons.
- LC27 requires SL to ensure that a plant is not operated, inspected, maintained or tested unless suitable safety mechanisms, devices and circuits (SMDC) are properly connected and in good working order.
- LC28 requires SL to make and implement adequate arrangements for the regular and systematic examination, inspection, maintenance and testing of all plant which may affect safety.
The intervention also examined compliance with relevant statutory provisions made under the Health and safety at Work etc. Act 1974 (HSWA). In particular this focused on examining compliance with the Lifting Operations and Lifting Equipment Regulations 1998 (LOLER) however other related RSPs were also discussed.
It should be noted that the inspection focussed primarily on the arrangements associated with the lift that was witnessed by the inspectors. Those arrangements were deemed to be adequate. The arrangements for the other, significant number of lifting equipment within the facility were noticeably less well-developed in places and regulatory issues have been created to track their improvement. ONR supports the work planned by HLWP to bring their wider lifting arrangements up to the required standard.
Explanation of Judgement if Safety System Not Judged to be Adequate
Based upon the areas sampled I judge that the safety case requirements for HLWP lifting arrangements have been adequately implemented.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
For LC7, I targeted the Management Investigation report, which had been commissioned following a high number of incidents within the HLWP facility. I concluded that several actions had not been absolutely closed out but had instead been transferred to another piece of work, which may be ongoing. I judged this to be a minor shortfall and raised one Level 4 regulatory issue to resolve it. I therefore judge that an inspection rating of Green (no formal action required) is merited.
For LC10, I targeted the training records associated with the operational team that carried out the lifting operation that we witnessed. As a result of our enquiries SL identified that the lifting supervisor had not completed ‘Management of Lifting Operations’ training which is required for his role. I viewed this to be a minor omission to an otherwise comprehensive training portfolio; therefore I did not view it appropriate to raise an ONR issue. I therefore judge that an inspection rating of Green (no formal action required) is merited.
For LC15, I sampled asset management information of the VPS 50te crane, design information for the Waste Vitrification Plant (WVP) Product Flask, and general Vitrified Product Store (VPS) Out Cell Cranes. The safe drop height of the Product Flask is a key operational parameter but I discovered that the justification for it was questionable and key supporting information was missing. I therefore raised a Level 4 regulatory issue to remedy this issue. On balance and based on the sample inspected, I judge that an inspection rating of Green (no formal action required) is merited.
For LC23 and 24, I targeted the safety case, which identified a number of limits and conditions associated with lifting operations and operating instructions associated with the witnessed lift, including emergency operating instructions. Overall I viewed that SL had appropriately implemented the safety analysis, principally via engineered means and that instructions were reasonable and in line with my expectations. Overall I viewed that SL’s implementation of their limits & conditions and the operating instructions was appropriate with no observations raised. An inspection rating of Green (no formal action) was given against LC23 & 24.
For LC26, I targeted the control and supervision of the lifting of the empty product flask. It was noted that the lifting operation was conducted in an efficient and safe manner with no cause for concern witnessed. It was also noted that the facility was undergoing a programme of training to increase the number of Lifting Operations Appointed Persons (LOAPs). I viewed that SL had appropriate control and supervision over the lifting operations sampled and that their control and supervision arrangements had been strengthened recently and appeared to be further improving. An inspection rating of Green (no formal action) was given against LC26.
For LC27, I targeted the safety related equipment associated with the 50 tonne crane used for the witnessed lift. I reviewed the facility’s safety case and identified appropriate SMDCs, whilst I was not able to gain access to inspect them, I did witness the ‘10x10’ brake test, which confirmed the good working order of that safety mechanism. During the plant walk-down I witnessed that the plant appeared to be appropriately marked up regarding safety mechanisms and other safety related equipment. From the limited number of safety mechanism sampled during this inspection I was content that SL has appropriately identified SMDC associated with lifting operations and that SL has arrangements to ensure that these are connected and in good working order. An inspection rating of Green (no formal action) was given against LC27.
For LC28, I targeted the examination, inspection, maintenance and testing (EIM&T) of the VPS 50 tonne crane; and the lifting arm associated with the lift witnessed. I also sampled the facility database for examples of EIM&T on other pieces of lifting equipment and their technical basis of maintenance (TBoM). I enquired after the TBoMs of several items of lifting equipment and found that they did not exist. I noted that HLWP has a plan to create TBoMs for all appropriate lifting equipment. I interrogated the SL asset management database (SAMdb) interactively and noted that the corresponding system health report (SHR) for many items was not available. I found that whilst appropriate EIM&T is undertaken, the majority of the facility’s lifting equipment is not recorded on the database. I noted that the facility has a plan to add all appropriate lifting equipment to the database. I consider the lack of TBoMs for safety related equipment and the poor uptake of the use of SAMdb to be a gap in HLWP arrangements and so I raised one L4 regulatory issue to track this improvement. On balance I was content with the examination, inspection, maintenance and testing being undertaken within the facility. I therefore judge that an inspection rating of Green (no formal action required) is merited.
For LOLER and other RSPs; I targeted LOLER regulations 7 to 10 (marking of lifting equipment; organisation of lifting operations; thorough examination and inspection; and inspection reports and defects); and Provision and Use of Work Equipment Regulations 1998 (PUWER), Regulation 5 (maintenance). I raised two regulatory issues. The first was related to the failure to record pre-use checks on Mobile Elevating Work Platforms (MEWPs). In addition I raised a second level 4 issue regarding maintenance as I noted that Category B defects identified by the Competent Person during the statutory Thorough Examination were not being acted upon in a timely manner as required by the regulations and SLMS.
The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.
Conclusion of Intervention
From the evidence gathered during this intervention, I do not consider there to be any matters that have the potential to impact significantly on nuclear safety. I judge that LCs 7, 10, 15, 23, 24, 26, 27 and 28 are being adequately complied with. I also judge that compliance against LOLER and other relevant statutory provisions is adequate.
I have raised 5 Level 4 Regulatory Issues. The issues are concerned with LC7 (Incidents on the site); LC15 (Periodic review); LC28 (Examination, inspection, maintenance and testing); LOLER Regulation 8 - Organisation of lifting operations; and PUWER 1998, Regulation 5 – Maintenance.