The Office for Nuclear Regulation (ONR) undertakes all regulatory interactions with Sellafield Limited (SL, the site licensee) against a strategy defined by the ONR Sellafield Programme. My planned inspection schedule for the current regulatory year (covering April 2016 - March 2017), the content of which is guided by that strategy, identifies the Licence Conditions (LCs) that will be inspected over this period.
This planned intervention was undertaken to determine if the Decommissioning Directorate is adequately implementing SL's site-wide arrangements and facility specific arrangements for compliance with Licence Condition 8 (warning notices). The intervention targeted the Magnox Swarf Storage Silo (MSSS), a facility about to undertake operations to retrieve stored wastes from the silos as part of the hazard and risk reduction programme at Sellafield. It is important, therefore, that the facility warning notices are in place, that the location of any exit is clearly signed and that the measures to be taken in the event of a fire or any other emergency are posted where they can be conveniently read. This will provide ONR confidence that the Licensee's response to any foreseeable event will be adequate and effective.
Licence Condition 8 (LC8) requires the licensee to make and implement adequate arrangements for ensuring that suitable and sufficient notices are kept on MSSS for the purposes of informing anyone of the meaning of any warning signal used in MSSS, the location of any exit from MSSS to be used in an emergency and any measures a person should take in the event of fire or any other emergency.
My inspection, which comprised discussions with SL staff, examination of plant documentation, and an inspection of the MSSS facility, focussed on the following areas:
Not applicable; this was not a Safety System inspection.
It is my opinion that the licensee has adequately implemented its arrangements for compliance with LC8.
I consider MSSS's implementation of the site's arrangements for LC8 is good in some areas; for instance, the staff interviewed had a good knowledge of the extant arrangements and were actively improving the arrangements in MSSS. They were able to provide some good supporting evidence such as schedules of signs and their maintenance. The use of regular inspections of the signage provides confidence that the signage will remain suitable and sufficient in the MSSS facility during and after transition to waste retrievals. This is, however, offset by the need for minor improvements such as improving the definition and provision of training for Building Managers; coordination of the Building Manager with Construction Supervisors and contractors to ensure signage remains current; the culture in the MSSS facility to stop the inadvertent obscuring of warning notices; rationalisation of warning notices on B*** and consistency of use of the temporary signage procedure.
Consequently, on balance, I consider the inspection merits an IIS rating of GREEN (no action required) against LC8.
My findings regarding those areas where minor improvements could be made were accepted by the MSSS facility team.
My findings were shared with, and accepted by, the licensee as part of normal inspection feedback. I will follow up the training observation regarding SL's OPMS system with ONR's Corporate Inspector. SL MSSS Senior Operations and Maintenance Manager has already taken action to include the Building Manager in the daily Plant Operations Control Centre (POCC) meetings to improve coordination with Construction Supervisors and contractors and the improvement programme is being implemented. Hence, I do not consider any further regulatory action to be necessary.