Date(s) of inspection: February 2024
Executive summary
Aim of inspection
The aim of the inspection is to consider UUK's implemented measures to prevent, control and mitigate fire hazards affecting both nuclear safety and life safety. This includes reviewing Springfield's examination of fires through their safety case documentation as well as building fire risk assessments and arrangements for compliance with the Regulatory Reform (Fire Safety) Order.
Subject(s) of inspection
- LC10 - Training - Rating: Green
- LC23 - Operating rules - Rating: Red
- LC24 - Operating instructions - Rating: Green
- LC27 - Safety mechanisms, devices and circuits - Rating: Green
- LC28 - Examination, inspection, maintenance and testing - Rating: Green
- Regulatory Reform (Fire Safety) Order 2005 - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
This was a planned inspection at the Capenhurst Site. The nuclear site licence holder is Urenco UK Limited (UUK). The inspection was undertaken as part of the intervention strategy for Decommissioning Fuel and Waste Sub-Division.
Fire hazards, if not controlled, can present risks to safety (nuclear and conventional). It is therefore important that the risks from fire are suitably controlled. This Fire Safety (FS) inspection at Capenhurst Site considered both Nuclear and Life Fire Safety (LFS) covering Buildings E23, A3 and Building 100. It was undertaken by the Nominated Site Inspector and fire safety specialist inspectors to determine whether fire risks at site are suitably controlled.
The inspection focussed on the implementation of arrangements for managing fire risks by reviewing compliance against the requirements of the Regulatory Reform (Fire Safety) Order 2005 (FSO) and compliance against the requirement of Licence Conditions (LC) LC10 Training, LC23 -Operating Rules, LC24 - Operating Instructions, LC27 - Safety Mechanisms, Devices & Circuits & LC28 - Examination, Inspection, Maintenance and Testing. The LC23 and LC24 parts of the inspection focussed on the nuclear fire safety case and its implementation. The LC10, LC27 and LC28 parts of the inspection focussed on the implementation of any derived safety measures relevant to fire safety within the safety cases and life safety arrangements.
The inspection focussed on the implementation of arrangements for managing fire risks by reviewing compliance against the requirements of the Regulatory Reform (Fire Safety) Order 2005 (FSO) and compliance against the requirement of Licence Conditions (LC) LC10 Training, LC23 -Operating Rules, LC24 - Operating Instructions, LC27 - Safety Mechanisms, Devices & Circuits & LC28 - Examination, Inspection, Maintenance and Testing. The LC23 and LC24 parts of the inspection focussed on the nuclear fire safety case and its implementation. The LC10, LC27 and LC28 parts of the inspection focussed on the implementation of any derived safety measures relevant to fire safety within the safety cases and life safety arrangements.
LC10 - Training
I sampled the training records for a UUK Systems Engineer and a contactor that fulfil roles associated with the fire alarm and detection system. I considered that UUK is adequately implementing its training arrangements as staff were trained to carry out the fire related aspects of their role. I judge that UUK is adequately implementing its arrangements with respect to Training and award a Green rating for LC10.
LC23 Operating Rules
I sampled the extant safety case and conducted a walkdown for Plant A3. The inspection identified significant shortfalls with the adequacy of the extant safety case both from a nuclear fire perspective, and more generally, with respect to the licensee maintaining and implementing an up-to-date safety case. I judge that UUK is not undertaking operations at Plant A3 in compliance with an adequate safety case and gave a Red rating against LC23. An Enforcement Letter ONR-EL-23-054 and associated Level 2 Regulatory Issue RI11969 have been raised in order to address the issues found.
LC24- Operating Instructions
I sampled UUK’s implementation of the fire safety requirements of the extant safety case in regards to the provision of automatic fire alarm and detection systems in Plant A3 building. I judge that UUK is adequately implementing its arrangements with respect to Operating Instructions and award a Green rating for LC24 noting that the derived requirements are likely to be inadequate based on LC23 compliance.
LC27- Safety Mechanisms & LC28 -Examination, Inspection, Maintenance and Testing (EIMT)
I sampled elements of the fire alarm and detection system while out on plant and by reviewing maintenance records to gain assurance that these systems would provide adequate protection to personnel against the potential effects of fire. I considered that the equipment was suitably connected and maintained and judge that UUK is adequately implementing its arrangements with respect to EIMT and award a Green rating for LC27 & LC28. Noting again that the derived maintenance schedule for fire related SSCs is unlikely to be adequate based on LC23 compliance.
Regulatory Reform (Fire Safety) Order 2005 (FSO)
The inspection consisted of examination of the licensee’s arrangements regarding LFS through review of documentation including Fire Risk Assessments, training and maintenance records, building walkdowns as well as meetings to assess the implementation and management of LFS at a site level.
I noted that the Fire Risk Assessments (FRA) sampled as part of the inspection were of an adequate quality and level of rigor. Maintenance records for fire systems were inspected and found to be adequate.
No significant shortfalls were identified during the facility walkdowns and each area was found to be in an adequate condition.
I judge that UUK is adequately implementing its arrangements with respect to Life Fire Safety and award a Green rating with regards to compliance with the requirements of the Regulatory Reform (Fire Safety) Order 2005 (FSO).
Conclusion
Regulatory Reform (Fire Safety) Order 2005
Overall, I found that UUK’s existing arrangements for Life Fire safety made under the requirements of the Regulatory Reform (Fire Safety) Order 2005 are adequate for controlling risks related to fire hazards.
During the inspection I raised several areas of advice or observations. However, these do not significantly impact on the overall adequate provision of safety.
I judge that UUK is adequately implementing its arrangements with respect to Life Fire Safety and award a Green rating with regards to compliance with the requirements of the Regulatory Reform (Fire Safety) Order 2005 (FSO).
Licence Conditions LC10 Training.
Overall, based on my sample, I judge that UUK is adequately implementing its training arrangements and staff are either trained or in the process of undertaking the training currently identified as necessary to carry out the fire related aspects of their role. I therefore award a Green rating.
LC23 Operating Rules
Plant A3 is implementing a safety case based on the 2008 Continued Operation Safety and Environmental Report (COSER). The extant safety case is not being maintained with suitable rigour and qualitatively dismisses nuclear fire fault sequences as ‘incredible’.
The 2018 A3 COSER for Plant A3 has not been implemented but is significantly different to the 2008 A3 COSER and raises a number of Safety Significant Shortfalls and Recommendations in relation to nuclear fire safety which further reflect on the adequacy of the extant safety case.
The 2018 COSER considers fire involving combustible cladding associated with plant A3 in terms of fire prevention but does not consider the implication of a developing fire in terms of potential building collapse and nuclear safety which raises doubts regarding the adequacy of this assessment.
Overall, based on my sample, I judge that UUK is not adequately implementing its arrangements with respect to Operating Rules and award a Red rating for LC23. An Enforcement Letter ONR-EL-23-054 and associated Level 2 Regulatory Issue RI 11969 have been raised in order to address issues found.
LC24 - Operating Instructions.
LC24 has been considered in terms of what the extant safety case considers as the only fire safety related plant which is fire alarm & detection system (FADS).
I sampled implementation of the fire safety requirements of the extant safety case in regards to the provision of automatic fire alarm and detection systems. I judge that UUK is adequately implementing its arrangements with respect to Operating Instructions and award a Green rating for LC24.
LC27- Safety Mechanisms & LC28 Examination, inspection, maintenance and testing (EIMT)
UUK states that the only fire safety related plant identified in buildings within scope of this inspection are the fire alarm & detection system (FADS). Based on my sample adequate evidence regarding management, maintenance and provision of FADS was provided during inspection and therefore I judge that UUK is adequately implementing its arrangements with respect to LC27- Safety Mechanisms & LC28 Examination, inspection, maintenance and testing (EIMT) and award a Green rating.