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, Decommissioning, Fuel and Waste 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) and other legal requirements that will be inspected over this period.
This intervention targeted the implementation of Sellafield Ltd's arrangements for compliance with the Ionising Radiations Regulations 1999 (IRR99) within the Analytical Services facility on the Sellafield site. This laboratory provides analytical services to other facilities across the site, receiving samples for assessment and characterisation on a routine basis. The work of the facility is important to ensuring that these other facilities remain within their safe operating envelopes, as well as characterising waste associated with hazard and risk reduction across the site. In addition, the Analytical Services facility, which comprises a number of laboratories, contains a significant radioactive inventory within its cells, gloveboxes, and fumehoods. The facility also contains legacy waste which is subject to a disposal programme under regulatory oversight.
The Ionising Radiations Regulations 1999 identify the duties on radiation employers etc. to protect people from the risks associated with ionising radiations. My planned inspection comprised discussions with SL, examination of plant documentation and a targeted plant walk-down. I was supported in this inspection by a radiological protection specialist inspector.
Prior to the inspection, I had liaised with SL on the focus of the inspection, and in particular had identified that this inspection would be a follow up activity to the IRR99 inspection undertaken in July 2015. Following this previous inspection, I had raised a Regulatory Issue which detailed a number of shortfalls against legal requirements, where Sellafield Ltd was required to make improvements. I have subsequently, regularly monitored progress against the associated actions, but decided to undertake this follow-up inspection as a targeted activity because of the importance of this topic area and the facility.
The licensee provided a summary of the activities undertaken by Analytical Services and its arrangements for ensuring compliance with IRR99. Matters discussed included risk assessments, work instructions, control measures for restricting the spread of contamination, training and supervision of personnel and the radiological monitoring of personnel and articles. I then carried out a plant visit to identify whether the licensee's arrangements were being effectively implemented at the point of work.
Not applicable; this was not a Safety System inspection.
I consider that the licensee has effectively implemented some of its arrangements for compliance with IRR99 within the Analytical Services facility; but there remain known shortfalls which are captured by the extant Regulatory Issue. I have also added one further action to this Regulatory Issue reflecting an additional shortfall which I have identified.
I consider the facility's implementation of the site's arrangements for compliance with IRR99 is good in many areas. For instance, SL has recently purchased some new radiological monitoring equipment, its staff were knowledgeable regarding the inspection subject area and provided many good quality responses to my questions., This, however, is offset by the required improvement work currently outstanding in this area; which SL understands and relates to the issue of revised operator instructions, completion of staff training, and shortfalls against relevant good practice for the facility sub-changeroom. For these reasons, on balance, I consider the inspection merits an IIS rating of Amber (Seek Improvement), against IRR99.
My findings were shared with, and accepted by, the licensee as part of normal inspection feedback. I have raised no new Regulatory Issues as a result of this inspection, although I have added a further action to an existing Regulatory Issue.