Executive summary
Date(s) of inspection: March 2024
Aim of inspection
To gain confidence that Sellafield Ltd. is compliant with Licence Condition (LC)10, 23, 24 and 28 (specifically in relation to nuclear fire safety) and the Regulatory Reform (Fire Safety) Order 2005 within the Encapsulation Plants facilities at the Sellafield site to inform a regulatory judgement regarding the licensee’s compliance with its legal duties.
Subject(s) of inspection
- Fire (Life Safety) Compliance Inspection - Rating: Amber
- LC10 - Training - Rating: Green
- LC23 - Operating rules - Rating: Green
- LC24 - Operating instructions - Rating: Amber
- LC28 - Examination, inspection, maintenance and testing - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
The inspection was undertaken on 19 and 20 March 2024. The inspection team comprised of the Encaps site inspector, two internal hazards specialist inspectors, one internal hazards and life fire specialist inspector and an inspector in training. The inspection targeted compliance against Licence Conditions (LCs) 10 (Training), 23 (Operating rules), 24 (Operating Instructions) and 28 (Examination, inspection, maintenance and testing), specifically in relation to nuclear fire safety, and compliance with the Regulatory Reform (Fire Safety) Order 2005.
The inspection involved a planning phase and a site visit, which included facilities walkdown, discussions with relevant Sellafield Limited personnel, review of records, and sampling of information contained within electronic databases and other documentation.
Based on the evidence sampled, we concluded the following:
One matter was identified that required immediate regulatory attention. This was the potential occupancy of an inner room office accessed via the 4th floor tank room in B396. Following the inspection, the facility has confirmed that the room is not currently occupied and has issued communications and signage to prevent future occupation while the elevated risk remains.
For LC10 we identified no shortfalls that require regulatory attention. Rated green.
For LC23 we didn't identify any Operating Rules on any of the Encaps facilities that directly related to Nuclear Fire. Rated green.
For LC24 we noted that the Nuclear Fire Safety Assessment (NFSA) for the Magnox Encapsulation Plant (MEP) was not adhered to and significantly out of date. We did however note that the actual nuclear fire safety risk is relatively low and as such it would be disproportionate to rate this as Red but an amber rating is appropriate with a Level 3 Regulatory Issue to ensure the NFSA is brought up to date is appropriate.
For LC28 we noted that similarly to LC24, the MEP NFSA designates Safety Mechanisms that are no longer considered to be required and hence aren't maintained as Safety Mechanisms. We consider that this issue is addressed in the comments for LC 24 above and hence have rated this as green based on our inspection of the maintenance taking place.
For the Regulatory Reform (Fire Safety) Order 2005, we identified shortfalls against combustible load management and the implementation and review of key fire safety requirements and managerial controls written in the fire strategies. Regulatory issues RI-11981 and RI-11982 have been raised to address these issues.
Fire Damper remediation work and the supporting processes has progressed well. The inspection has provided sufficient evidence to close Action 2 of RI-11151, to repair and replace defective dampers in B396.
The inspection has been rated amber against the Regulatory Reform (Fire Safety) Order.
Conclusion
License conditions
For LC10 we identified no shortfalls that require regulatory attention. Rated green.
For LC23 we didn't identify any Operating Rules on any of the Encaps facilities that directly related to Nuclear Fire. Rated green.
For LC23 we didn't identify any Operating Rules on any of the Encaps facilities that directly related to Nuclear Fire. Rated green.
For LC24 we noted that the Nuclear Fire Safety Assessment (NFSA) for the Magnox Encapsulation Plant (MEP) was not adhered to and significantly out of date. We did however note that the actual nuclear fire safety risk is relatively low and as such it would be disproportionate to rate this as Red but an amber rating is appropriate with a Level 3 Regulatory Issue to ensure the NFSA is brought up to date is appropriate.
For LC28 we noted that similarly to LC24, the MEP NFSA designates Safety Mechanisms that are no longer considered to be required and hence aren't maintained as Safety Mechanisms. We consider that this issue is addressed in the comments for LC24 above and hence have rated this as green based on our inspection of the maintenance taking place.
Life Fire Safety
In our judgement, while the facility has made progress against some of the fire systems non-compliances it has identified, there remain gaps against good practice for fire safety design and fire safety management at the facility.
We recognise the fire systems progress made by the facility and will close the relevant action in RI-11151.
We will raise Level 4 RI-11981 requiring a refocus on housekeeping and combustible load management, including on the non-active side
We have considered the gap against the fire strategy key requirements in EDR ONR-EDR-23-094 and will raise Level 3 RI-11982 to monitor improvement in this area.
We have rated the inspection amber against the Regulatory Reform Fire Safety Order.