- Site: Sellafield
- IR number: 21-110
- Date: October 2021
- LC numbers: 17
Executive summary
Purpose of Intervention
Sellafield Limited has requested ONR agreement to commence active commissioning of the waste retrievals plant installed on Pile Fuel Cladding Silo (PFCS) compartment 5 and on Magnox Swarf Storage Silo (MSSS) compartment 10. Sellafield Limited propose to retrieve waste from PFCS compartment 5 and MSSS compartment 10 into 3m3 boxes, which will be stored in an interim facility until further processing and final disposal in a Geological Disposal Facility (GDF). Sellafield Limited is undertaking a phased procurement process for 3m3 boxes. One of the suppliers initially contracted to manufacture the 3m3 boxes is Stainless Metalcraft (SMC) Limited.
The purpose of this inspection was to sample evidence to gain assurance that Sellafield Limited’s Supply Chain Management arrangements (LC 17, Management systems) were being adequately implemented for the manufacture of 3m3 boxes at SMC to meet Sellafield Limited’s programme for the supply of 3m3 boxes. The findings from this inspection will be used to inform the decision in response to Sellafield Limited’s request for ONR agreement to commence active commissioning of the waste retrieval equipment installed on PFCS compartment 5 and MSSS compartment 10.
Interventions Carried Out by ONR
The inspection was undertaken on the 20 and 21 October 2021 by a Mechanical Engineering Specialist Inspector, a Supply Chain Inspector, a Quality Specialist Inspector and a Chemistry Specialist Inspector. The inspection comprised discussions with SMC and Sellafield Limited staff, review of a targeted sample of SMC and Sellafield Limited’s documentation and a manufacturing facility visit.
LC17 requires Sellafield Limited to make and implement management systems which give due priority to safety. Within its management systems, Sellafield Limited is required to make and implement adequate quality management arrangements in respect of all matters which may affect safety.
As part of the preparation for the delivery of this intervention, the following formal ONR guidance documentation and Relevant Good Practice (RGP) was used:
- NS-TIG-GD-017: Management Systems;
- NS-TAST-GD-077: Supply Chain Management Arrangements for the Procurement of Nuclear Safety Related Items or Services;
- NS- TAST-GD-049: Licensee Core Safety and Intelligent Customer Capabilities;
- NS- TAST-GD-079: Licensee Design Authority Capability;
- IAEA-TECDOC-1910 Quality Assurance and Quality Control in Nuclear Facilities and Activities Good Practices and Lessons Learned;
- IAEA - NP-T-3.21 – Procurement Engineering and Supply Chain Guidelines in Support of Operation and Maintenance of Nuclear Facilities; and
- Safety Directors Forum - Supply Chain Quality Requirements.
The scope of the inspection included Sellafield Limited’s supply chain strategy and management approach; 3m3 box specifications; SMC organisational & technical capability; SMC manufacturing capacity; management of deviations from specification and concessions; control of manufacturing; mitigation of the risks from Counterfeit, Fraudulent and Suspect Items (CFSI); and a facility walk down.
Explanation of Judgement if Safety System Not Judged to be Adequate
Not applicable, as this was not a System Based Inspection.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
No significant matters were identified as requiring immediate regulatory attention in relation to the implementation of the LC 17 arrangements for the procurement of 3m3 boxes from SMC.
We noted minor observations related to the following:
- Sellafield Limited should provide confidence that it can produce a Legacy 3m3 box by June 2022 to enable inactive commissioning of Box Encapsulation Plant (BEP) facility;
- Sellafield Limited should consider if its frequency of reviewing open Product Permits (PPs) and concessions is appropriate as part of its readiness review for phase 2 transition and phase 2 volume manufacture of 3m3 boxes;
- Sellafield Limited should consider if its arrangements for the management of Lifetime Quality Records (LTQRs) for MSSS and PFCS 3m3 boxes are sufficient for the duration of interim storage and final disposal.
We were of the opinion that this potential shortfall does not warrant the raising of a regulatory issue. The above observations will be followed-up by the ONR Project Inspector via routine regulatory engagements.
We noted three particular areas of good practice, these were in relation to the approach to the collaboration between SMC and Sellafield Limited; the use of the Early Warning Notice (EWN) process, through which either Sellafield Limited or SMC can raise a concern that an issue or circumstance has arisen that could adversely affect the manufacture of 3m3 boxes; and, the use of posters and info boards on the manufacturing floor that identify the safety significant features of the MSSS and PFCS 3m3 boxes.
Our findings were shared with, acknowledged and accepted by SMC and Sellafield Limited staff involved in the inspection.
Conclusion of Intervention
Taking the above key findings into account, and noting the ONR guidance on inspection ratings, we judge that the Sellafield Limited has adequately implemented its arrangements for compliance with Licence Condition 17 (Management systems). We therefore consider that an inspection rating of Green (No Formal Action) is merited.