Executive summary
Date(s) of inspection: February 2024
Aim of inspection
ONR is engaged in periodic planned inspection of the ongoing construction of the Sellafield Product and Residue Store (SPRS) Retreatment Plant (SRP) facility pursuant to the requirements of the site licence conditions and wider statutory requirements under the Health and Safety at Work Act.
This engagement is designed to support ONR Sellafield Decommissioning Fuel and Waste objective, entitled: Regulation of key construction and new capability at Sellafield SIXEP Continuity Plant (SCP), SRP and Replacement Analytical Project (RAP) (CM9: 2023/49362).
This engagement comprises a rated readiness inspection for the proposed installation of eleven large prefabricated steelwork roof trusses at high level within the SRP building at Sellafield. The readiness inspection is part of ongoing regulatory oversight for the new construction pursuant principally to Licence Condition 19.The specific purpose of this readiness inspection is to gain confidence in the following matters relating to the proposed installation of the roof trusses of the SRP facility:
- Compliance with statutory requirements for the management of conventional and nuclear safety risks associated with the planned lifting operation.
- The risks to technical conformance with the execution design were being adequately controlled.
- Schedule risks were being adequately controlled to the extent that they might impact on overall hazard reduction for the Sellafield plant and, more specifically, that adequate progress was being made on enabling tasks.
Subject(s) of inspection
- CDM 15 - Rating: Green
- LC19 - Construction or installation of new plant - Rating: Green
- Lifting / LOLER - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
Installation of the steel roof trusses of the SRP project, at 32m span and 74 tonnes each, constitute a fairly major construction operation by industry standards. Spatial constraints and adjacent hazards present specific logistical challenge that have resulted in the introduction of winching operations; a measure that may be considered somewhat specialist in nature (but not novel).Accordingly, although there is no formal regulatory hold point on these activities it has been decided to take proportionate regulatory oversight of this activity by undertaking a construction readiness inspection.
The inspection was undertaken in a number of phases:
- Part 1: 14 February 2024 - A documentary review and short site visit for reconnaissance
- Part 1b: 28 February 2024 - Assessment of compliance with LOLER and CDM by a specialist conventional health and safety inspector
- Part 2 and 3: 20 March 2024 - Verifying physical readiness at the proposed lifting and landing sites
This inspection judged the adequacy of Sellafield Ltd.'s management of the construction works pursuant to its duty under License Condition (LC) 19 as well as compliance with the following:
- The Construction (Design and Management) Regulations 2015 (CDM)
- The Lifting Operations and Lifting Equipment Regulations 1998, Approved Code of Practice and Guidance (LOLER)
- British Standard 7121-1-2016, code of practice for safe use of cranes (BS-7212)
The inspection was undertaken and rated against published guidance on regulatory expectations, as described in ONR's technical inspection guides NS-INSP-GD-019 andONR-INSP-GD-064. Based on the evidence sampled at the time of the intervention against Sellafield Ltd.'s arrangements and documentation, and regulatory guidance ONR judged that Sellafield Ltd. demonstrated adequate compliance with LC19, LOLER and CDM.
Conclusion
Based on our findings from the available evidence, we judge that Sellafield Ltd's implementation of its LC19 arrangements, to install the SRP Roof Trusses, is adequate and management of the installation aligns with the requirements of LOLER and CDM.
In relation to Sellafield Ltd’s state of readiness, this inspection identified some areas that remain to be completed. This intervention provided us with confidence that Sellafield Ltd is in control of the completion of these planned activities, and there is a mature readiness review process in place to confirm completion prior to commencement of roof truss installation.
It is therefore judged that an inspection rating of Green (No formal action) is merited, in accordance with ONR Guide ONR-INSP-GD-064, where relevant good practice was met when compared with appropriate benchmarks; legal duties were complied with; and, no safety shortfalls were identified in the delivery of safety functions.