- Site: Sellafield
- IR number: 21-098
- Date: October 2021
- LC numbers: 17
Executive summary
Purpose of Intervention
The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Sellafield site licensee (Sellafield Limited) against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. The planned inspection schedule for 2021/22, identifies the Licence Conditions (LCs) that will be inspected during this period.
The purpose of this inspection was for ONR to determine the adequacy of implementation of Sellafield Ltd’s arrangements for compliance with LC 17 (Management systems) at the Spent Fuel Services Operating Unit focussing on one of the Fuel Storage Facilities (the latter being formerly the Oxide Fuel Storage Group (OFSG)).
The overall adequacy of Sellafield Ltd’s site-wide LC 17 arrangements is considered separately in other ONR interventions.
Interventions Carried Out by ONR
I, the Site Inspector for THORP and Fuel Storage carried out a planned LC 17 compliance inspection at a Spent Fuel Services Fuel Storage facility on 6-7 October 2021, utilising specialists from the following technical disciplines:
- Supply Chain; and
- Quality Management.
The inspection focused on Spent Fuel Services’ implementation of the Sellafield Ltd LC 17 arrangements for the procurement of 108 pin slotted cans, including:
- Acquisition Strategy;
- Issue of Specifications & Quality Assurance Arrangements;
- Contract Delivery; and
- Inspection & Goods Receipt.
The inspection comprised discussions with Sellafield Ltd staff, a review of records, the sampling of information contained within electronic databases and other documentation.
Explanation of Judgement if Safety System Not Judged to be Adequate
Not applicable since this was not a safety 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 at Spent Fuel Services (Fuel Storage).
I found that Fuel Storage demonstrated an adequate understanding of Sellafield Ltd’s site-wide arrangements for LC 17 and has adequately implemented these arrangements, including the implementation of quality management arrangements proportionate to the safety risk. In line with Sellafield arrangements and relevant good practice the 108 pin slotted cans have been assigned Quality Grade 2, and the requirements have been cascaded to the supplier via a Material Master and the Sellafield Ltd Contract Quality Requirements Manual. While the original contract has expired, Sellafield Ltd has taken steps to secure an adequate supply of 108 pin slotted cans in the short term whilst the next procurement is undertaken. Appropriate steps continue to be undertaken to build up a buffer stock of one year’s supply and Sellafield Ltd demonstrated that appropriate commercial contingency plans are in place in the event of supplier issues.
One shortfall was identified in relation to the adequacy of the implemented dimensional quality checks relating to the supply of P5f slotted cans and this will be followed up via a further action to an existing regulatory issue; I will also ask Sellafield Ltd to consider how any updated dimensional quality checks will apply to the existing stock. Furthermore, I will also revisit one of the existing actions to verify the justification of the underpinning mechanical design assessment associated with the maximum credible P5f can inner diameter.
I provided regulatory advice regarding the storage location of manufacturing quality records and the requirement to maintain compliance with arrangements made under LC 22 (Modification or experiment on existing plant) for modifications which may affect safety, in that LC 22 also applies to processes (which may affect safety) which are modified.
I also identified matters in relation to Sellafield Ltd’s corporate Intelligent Customer arrangements and how Sellafield Ltd considers manufactured products during periodic safety reviews; I will raise these with the ONR Corporate Inspectors for consideration.
My findings were shared with, acknowledged and accepted by Fuel Storage’s management as part of normal inspection feedback.
Conclusion of Intervention
On the basis of the evidence sampled at the time of the inspection, I judge that Spent Fuel Services has adequately implemented Sellafield Ltd’s arrangements for LC 17, with one shortfall identified. Noting the ONR guidance on inspection ratings, it is my opinion that an inspection rating of Green (no formal action) is merited. One extant Level 3 regulatory issue will be updated to manage the resolution of the identified shortfall.