- Site: Sellafield
- IR number: 21-152
- Date: January 2022
- LC numbers: 23, 24, 28
Executive summary
Purpose of Intervention
In accordance with the Office for Nuclear Regulation’s (ONR’s) Sellafield Ltd’s Strategy, each year ONR performs a series of intelligence informed inspections. The purpose of this particular intervention was to undertake an examination of the former Thermal Oxide Reprocessing Plant (THORP) Receipt and Storage Facility (TR&S), now the Interim Advanced Gas Reactor Fuel Receipt and Storage Facility (referred to as BXXX Receipt and Storage for the remainder of this intervention record) safety case related to dropped loads and compliance with Regulations 8 and 9 of the Lifting Operations and Lifting Equipment Regulations (LOLER) 1998.
The intervention was linked to findings from lifting interventions by the ONR site safety and mechanical engineering specialisms in 2019 and 2020, which identified shortfalls in the site’s LOLER compliance. Consequently, ONR decided to sample the status of dropped load safety case implementation under the auspices of Licence Conditions (LCs) 23, 24 and 28 and LOLER compliance with Regulations 8 and 9 at two of the Sellafield Ltd facilities, BXXX Receipt and Storage and the Fuel Handling Plant. This intervention record documents the intervention at the BXXX Receipt and Storage Facility.
Interventions Carried Out by ONR
We, the Site Inspector for THORP and Fuel Storage, an Internal Hazards Inspector and a Conventional Health and Safety Inspector undertook a planned two-day inspection at BXXX Receipt and Storage covering the safety case arrangements (LC23, LC24 and LC28) and LOLER 8 and 9 compliance on 12 and 13 January 2022.
The inspection involved reviewing the applicable claims in the safety case and arrangements, and then sampling evidence to determine compliance against the selected LCs and regulations at the facility. This was achieved through a combination of document reviews, plant inspections and discussions with operations and maintenance staff.
We assessed compliance against the following LCs by using the applicable ONR inspection guidance documents:
- LC23 – Operating rules (NS-INSP-GD-023)
- LC24 – Operating instructions (NS-INSP-GD-024)
- LC28 – Examination, inspection, maintenance and testing (NS-INSP-GD-028)
- L113 - Safe Use of Lifting Equipment Approved Code of Practice – Lifting Operations and Lifting Equipment Regulations 1998
- BS 7121-1:2016 Code of Practice for Safe Use of Cranes
Explanation of Judgement if Safety System Not Judged to be Adequate
N/A.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
We found that there are clear links between the safety case hazard analysis documents (HAZANs), the Clearance Certificates, the Operating Instructions (embedded in Quality Plans) and in most instances compliance records. We are also of the opinion that there is adequate cross referencing, knowledge, and visibility of safety case requirements as Operating Rules (ORs) and required Operating Instructions (rOIs) associated with dropped load hazards both on-plant and in the Quality Plans. We did find that for one rOI there was not a demonstration of compliance within the associated Quality Plans; Sellafield Ltd informed us that there is a programme to review each of these Quality Plans and we saw evidence of this programme, but we have raised one L4 (lowest level) regulatory issue to track the demonstration of compliance with this rOI.
We found that, on the basis of the maintenance records sampled, that the safety mechanisms selected were being adequately maintained and the condition of the plant was understood. We also judge that appropriate measures are in place to repair known defects.
We found that the BXXX Receipt and Storage Facility is implementing the updated site arrangements for Regulation 8 of LOLER; a Lifting Operations Appointed Person is now in post, revised terminology is in place meeting the requirements of the relevant British Standard, and the lifting plans are being updated. However, it was evident that the revised terminology is still being communicated across the facility and we provided guidance to fully embed the new arrangements within the facility.
For Regulation 9, we found that the facility is compliant with the legal requirements, and there is also a proactive position being taken in response to less significant defects.
Consequently, it is our opinion that for this inspection a rating of GREEN (no formal action) is appropriate for LCs 23, 24, 28 and LOLER 8 and 9.
Our findings from the intervention were presented to and accepted by the Fuel Storage Senior Operations Manager.
Conclusion of Intervention
From the evidence sampled during the inspection, we judge that Sellafield Ltd has adequately implemented the relevant claims safety case for dropped loads at BXXX Receipt and Storage and is compliant with the requirements of LOLER 8 and 9. One Level 4 (lowest level) regulatory issue was raised in relation to demonstrating compliance with a limit and condition of operation.