- Site: Sellafield
- IR number: 21-128
- Date: November 2021
- LC numbers: 27, 28, 34
Executive summary
Purpose of Intervention
In accordance with the Office for Nuclear Regulation’s (ONR’s) Sellafield Strategy, each year ONR performs a series of planned compliance inspections of selected licence conditions, targeted at those facilities with significant importance to nuclear safety, and against the Control of Asbestos Regulations 2012, Regulation 4, targeted all those facilities with significant importance from the control of asbestos regulation perspective.
The purpose of this planned compliance inspection was to confirm that Sellafield Limited adequately implemented its arrangements for LC 27 (Safety mechanisms, devises and circuits), 28 (Examination, inspection, maintenance and testing), 34 (Leakage and escape of radioactive material and radioactive waste) and for the Control of Asbestos Regulations 2012, Regulation 4, at Calder Hall. In addition, the inspection sought evidence that effective strategies for characterisation, monitoring, trending, and analysis of ageing at facility, system and component level are present under Theme 1 of the Chief Nuclear Inspector’s themed inspection on ageing management.
Calder Hall which is currently under Surveillance and Maintenance (post de-fuelling safety case) has been selected partly because there is extensive evidence of ageing and partly because there is a planned acceleration for decommissioning and dismantling activities as part of the Calder Hall Land Clearance Project to make an area of the site available for re-development.
Interventions Carried Out by ONR
The inspection was undertaken on the 10 and 11 November 2021 by the ONR Site Inspector for the Remediation Value Stream, a Civil Engineering Specialist Inspector, a Mechanical Engineering Specialist Inspector and a Conventional Health and Safety Specialist Inspector. The walkdown part of the inspection was also attended by the Delivery Lead. The ONR inspectors were joined by an inspector from the Environment Agency and the Nuclear Intelligence and Independent Oversight inspector for waste.
This inspection sought evidence of compliance against LC 27, 28, 34 and against the Control of Asbestos Regulations 2012, Regulation 4. This was achieved through a combination of document reviews and sampling of records, discussions with operators and maintenance staff and plant inspection.
LC 27 requires the licensee to ensure that a plant is not operated, inspected, maintained or tested unless suitable and sufficient safety mechanisms, devices and circuits are properly connected and in good working order.
LC 28 requires the licensee to make and implement adequate arrangements for the regular and systematic examination, inspection, maintenance and testing of all plant which may affect safety.
LC 34 requires the licensee to ensure, so far as is reasonably practicable, that radioactive material and radioactive waste on the site is at all times adequately controlled or contained so that it cannot leak or otherwise escape from such control or containment. It also requires the licensee to ensure, so far as is reasonably practicable, that no such leak or escape of radioactive material or radioactive waste can occur without being detected, and that any such leak or escape is then notified, recorded, investigated and reported.
Regulation 4 of Control of Asbestos Regulations 2012 requires the licensee to identify the location and condition of asbestos and manage the risk to prevent harm to anyone who works on the building or to building occupants.
As part of the preparation for the delivery of this intervention, the following formal ONR guidance documentation was used:
- NS-INSP-GD-027 Revision 6 – Safety Mechanisms, Devices and Circuits;
- NS-INSP-GD-028 Revision 8 – Examination, Inspection, Maintenance and Testing;
- NS-INSP-GD-034 Revision 6 – Leakage and Escape of Radioactive Material and Radioactive Waste; and
- Managing and working with asbestos – Control of Asbestos Regulations 2012 – Approved Code of Practice and Guidance (L143).
Explanation of Judgement if Safety System Not Judged to be Adequate
This was not a system based inspection, and therefore no judgement has been made of the adequacy of implementation of any part of the safety case.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
In relation to LC 27, Calder Hall has recently implemented its Post De-fuelling Safety Case and is currently in the process of finalising the Operational Clearance Certificate Support Document and other operational and maintenance documentation. No operating rules, safety mechanisms or required operating instructions have been identifiedin the extant safety case with the reactor pile cap providing the only relevant safety function. Whilst the extant safety case is currently being reflected in all operational and maintenance documentation, the Operations Manager for Beta Gamma provided us with assurance that the Safety Case Implementation Plan (SCIP) will be fully implemented, and the NI&IO inspector for waste agreed to oversee the full implementation of the SCIP. On balance, based on the evidence sampled, as part of the inspection, we judge that the required standard is being met and an inspection rating of Green (no formal action) is appropriate against LC 27.
In relation to LC 28, we sampled evidence associated with the licensee’s compliance with its formal arrangements and sampled items identified in the safety case through the planned maintenance system. We were satisfied that the facility had followed their formal arrangements for LC 28, had derived a planned maintenance schedule and had a non-delivery process that was applied to those that could not be delivered on time. Whilst we observed a deterioration of the building envelope for several buildings, Sellafield Limited is confident that the current maintenance activities capture the condition of the plants and appropriate care and maintenance is in place. Addressing this matter in the longer term is being followed-up by an existing regulatory issue (8335) and other ongoing LC 35 regulatory interventions. On balance, based on the evidence sampled, as part of the inspection, we judge that the required standard is met and an inspection rating of Green (no formal action) is appropriate against LC 28.
In relation to LC 34 the licensee confirmed that there is no specific equipment identified, in the extant safety case, which provides a role in preventing or detecting leakage and escape of radiological material under LC 34. Nevertheless, we sampled several areas (mortuary tubes analysis of groundwater samples, the drainage system and discharge bay effluent system) and we were satisfied that the required standard is met and an inspection rating of Green (no formal action) is appropriate against LC 34.
In relation to asbestos management at Calder we found the arrangements to be comprehensive and to meet the requirements of Regulation 4 of the Control of Asbestos Regulations 2012. A good level of management of control of Asbestos Containing Materials (ACMs) within the facility was also demonstrated. We were satisfied that the required standard is met and an inspection rating of Green (no formal action) is appropriate against Regulation 4 of the Control of Asbestos Regulations 2012.
In relation to Theme 1 of the Chief Nuclear Inspector’s themed inspection on ageing management we were satisfied that effective strategies for characterisation, monitoring, trending, and analysis of ageing at facility, system and component level were present.
Conclusion of Intervention
Taking the above key findings into account, and noting the ONR guidance on inspection ratings, we judge that the licensee has adequately implemented its arrangements for compliance with Licence Condition LC 27 (Safety mechanisms, devises and circuits), 28 (Examination, inspection, maintenance and testing), 34 (Leakage and escape of radioactive material and radioactive waste) and Regulation 4 of the Control of Asbestos Regulations 2012. We therefore consider that an inspection rating of Green (No Formal Action) for each of the Licence Conditions (27, 28 and 34) and for Regulation 4 of the Control of Asbestos Regulation 2012 is merited.