Executive summary
- Inspection date(s): 13/07/22
Purpose of inspection
The aim of the intervention is to: gain assurance that Fellside have suitable and sufficient arrangements to respond to emergency events and have incorporated learning from from a power dip event in 2020; ensure Sellafield have adequate control and supervision of operations that affect nuclear safety in Fellside; and ensure maintenance is appropriately scoped and adequately implemented.
Subject(s) of inspection
The following actives were the subject of this inspection:
- LC12 - Duly authorised and other suitably qualified and experienced persons - Rating - Green
- LC26 - Control and supervision of operations - Rating - Green
- LC28 - Examination, inspection, maintenance and testing- Rating - Green
Key findings
This intervention was conducted at Fellside Combined Heat and Power (FCHP) Plant which is operated by Px on behalf of Sellafield.
I conducted a Licence Condition 12, 26 and 28 Compliance Inspection within FCHP Plant which was informed by learning from a power dip event in 2020.
The inspection was planned and was undertaken in accordance with ONR guidance (Office for Nuclear Regulation (ONR) Compliance inspection - Technical inspection guides).
No matters were identified as requiring immediate regulatory attention during the conduct of the compliance inspection.
No shortfalls or issues were found which significantly affect nuclear safety or were judged to be of such regulatory concern as to require immediate action.
In my opinion the process for training staff (Check off Books) and for the authorisation of person for key safety roles is consistent with good practice for LC 12.
I issued regulatory advice regarding potential improvements for the electronic recording of maintenance. I raised a level 4 regulatory issue (lowest level) for Sellafield to confirm the continued applicability of an Operating Rule at Fellside Combined Heat and Power Plant.
On the basis of the evidence obtained during the inspection I have given an inspection rating of green (no formal action) for LC12 (duly authorised and other suitably qualified and experienced persons), LC 26 (control and supervision of operations) and LC 28 (examination, maintenance and testing).
Judgements made
On the basis of the evidence obtained during the inspection I have given an inspection rating of green (no formal action) for LC12 (duly authorised and other suitably qualified and experienced persons), LC 26 (control and supervision of operations) and LC 28 (examination, maintenance and testing).
Licence Condition 12
In my opinion the Check off Book (COB) and SAP authorisation process align to the requirements of a duly authorised person (DAP) and are consistent with good practice.
Licence Condition 26
In my opinion the clear articulation of roles and responsibilities for maintenance and operations is consistent with good practice.
There are clear categories for maintenance according to importance and an appropriate level of oversight from Sellafield Ltd.
The COB and isolation that were sampled were evidence of appropriate implementation.
Licence Condition 28.
The Sellafield documentation states that there is an Operating Rule (OR) (STEAM/OCC/001-OR/01) on Fellside relating to the steam supply to High Active Liquor Evaporation and Storage (HALES).Px reported that there are no specific operations that affect safety formally identified at FCHPP. In my opinion this is not consistent with the contents of the OR as LC23(3) states the licensee shall ensure that operations are at all times controlled and carried out in compliance with Operating Rules. Representatives from Sellafield stated that the OR is under review. The operational performance of Px at FCHPP and the designation of plant as 'operationally critical' with associated maintenance and control provides reassurance that the broad intent of LC23 is likely to be met.I will raise a Level 4 Regulatory Issue (lowest level) as this issue challenges regulatory compliance with LC23(3).
In my opinion the categorisation of maintenance according to safety or operational significance is consistent with good practice. The sampled maintenance records are evidence that maintenance has been completed and legal requirements have been met. I provided regulatory advice on record management within the Maximo maintenance management system.