Executive summary
Date(s) of inspection: September 2024
Aim of inspection
The aim of this intervention is to seek assurance that operations related to lifting internal transfer flasks at the Fuel Handling Plant (FHP) are undertaken safely.
Subject(s) of inspection
- LC10 - Training - Rating: GREEN
- LC24 - Operating instructions - Rating: RED
- LC26 - Control and supervision of operations - Rating: Not Rated
- LC28 - Examination, inspection, maintenance and testing - Rating: GREEN
- Lifting / LOLER - Rating: Not Rated
Key findings, inspector's opinions and reasons for judgement made
I, the Site Inspector for the Spent Fuel Services Operating Unit at the Sellafield Site in Cumbria and supported by a Mechanical Engineering Inspector, undertook an emergent inspection focussing on lifting operations for the Advanced Gas-Cooled Reactor Fuel Internal Transfer Flask at the Fuel Handling Plant. The inspection was related to the identification of a safety case shortfall regarding an insufficiently substantiated lift height, and had the aim of seeking assurance that lifting operations for the Internal Transfer Flask were safe and compliant. During the course of the inspection, and having observed a lift, I was of the opinion that the lifts were not in compliance with the conditions of the nuclear site licence and the knowledge of the emergency response to a drop was inadequate. As a result of my inspection, Sellafield Ltd voluntarily suspended operations relating to the lifting of the ITF with the aim of addressing my concerns.
I am satisfied with Sellafield's response to my findings and that the Licensee has brought itself back into compliance. In relation to the insufficiently substantiated lift, I will seek improvement utilising ONR's established enforcement arrangements.
During the course of the inspection I identified that maintenance has been undertaken on the associated cranes, and that the site's training arrangements were implemented, and have rated these two elements of the inspection as Green (no further action), however I have provided regulatory advice relating to the periodicity of the training. I was not satisfied with the use of written instructions to control the lifting, and the knowledge of the emergency instruction, that is also a written instruction in Sellafield's arrangements, and have rated the related licence condition as Red.
Conclusion
In coming to a judgement on LC24, I have considered ONR's General Inspection Guide, Appendix 9 and the following factors; (1) without an intervention on the day, there would have been no use of the written instructions as required by LC24; (2) there was ambiguity over the status of the written instructions; (3) the particular instruction is claimed in the safety case; (4) given the uncertainty with the substantiation, procedural arrangements will have a greater significance in ensuring safety; and (5) the risk to the operators should the flask drop and the lid detach would have a serious consequence. I therefore judge this LC as Red. I will now apply the ONR governance process to inform the most appropriate course of regulatory action
Based on the sampling of the maintenance and training arrangements, I am of the opinion that these have been implemented at Site and rate these as Green, however I have given regulatory advice in relation to the periodicity of training for emergency arrangements in relation to a flask drop.
For LC26 and LOLER I am of the opinion that I did not see enough evidence to rate them, but did have assurance that the limited areas I saw were compliant.