Plant visits and meetings to establish progress of Sellafield Ltd.’s arrangements for managing conventional health and safety (CHS), including legionella risk systems and health and safety during engineering activities.
One of ONR’s key strategic themes is influencing improvements in nuclear safety and security. The current Cross ONR Programme strategic direction for 2015-2020 contributes to this theme by providing coherent specialist conventional health and safety support and advice to other ONR regulatory programmes. This intervention forms part of a programme of work underway by the ONR Conventional Health & Safety (CHS) team to secure improvements in conventional health and safety management within the nuclear industry.
The key regulatory activities undertaken during the visits were based around:
Plant visits to the HALES and Engineering facilities were undertaken. The locations and topics covered were selected using regulatory intelligence gained from previous interventions at the facilities.
This intervention enabled ONR to verify progress by Sellafield Ltd. for a number of elements of CHS management rather than being a detailed inspection of one particular CHS topic across the Sellafield Ltd. organisation. The plant visits were planned in order to provide an opportunity to verify action taken by Sellafield Ltd to resolve or progress concerns previously highlighted by ONR regarding CHS management in the Engineering facility and management of the HALES cooling system as a legionella risk system. ONR has a regulatory issue open relating to the HALES cooling system, issue number 4006.
Sellafield provided ONR with relevant documentation prior to the visits. The documentation is saved in TRIM folder 4.3.548. or 4.7.11764. and is referenced in the relevant sections.
Regulatory judgement was based on determining compliance with sections 2, 3 and 6 of the Health & Safety at Work etc. Act 1974 and a number of relevant statutory provisions made under the Act.
Detailed findings, inspector opinion and reasons for judgements made regarding the ONR enquiries into the management of the HALES cooling system as a legionella risk system are not included in this record as the enquiries are ongoing.
The findings made, inspector opinion developed and judgements made during the plant visit to the Engineering facility were made using the relevant legislation or guidance on health and safety in engineering workshops as benchmark standards.
As per previous visits to the facility, it was evident that progress was being made to improve CHS management standards in the facility. For example, metal working fluids (MWFs) appear to be more robustly managed now, with nominated personnel responsible for monitoring the condition of MWFs. Lathes have been purchased to reduce use of portable grinding equipment, good for control of vibrating equipment. In addition, guarding reviews have been completed for older engineering equipment in the facility, with some taken out of use or new guards purchased and fitted as a result.
However, the facility continues to lag some way behind the standards expected of an engineering facility in a large organisation. Examples of other sites in the nuclear industry that Sellafield could benchmark themselves against were provided during the visit. Key issues identified during the plant visit included:
Initial feedback was provided at the end of each meeting and plant visit to the relevant Sellafield personnel.
Interim feedback was provided on the HALES cooling system and legionella topics that require additional action by Sellafield Ltd. including:
ONR stated that unless Sellafield can demonstrate that the HALES water treatment systems deliver effective water treatment for the HALES cooling system, Sellafield would have to review its assessment of risk for the system.
Regarding the plant visit to the Engineering facility – Due to prompt action by the facility to rectify some of the immediate safety concerns and a commitment given to complete further actions in a timely manner, the rating applied is ‘amber’, ie. inconsistent standards for managing risks to workers; with some key relevant statutory provisions not met.
Further clarification is being sought from Sellafield regarding the nature and extent of commitments made following the engineering facility plant visit. Consideration is being given to writing an enforcement letter for the priority actions identified relating to the Engineering facility. Action progress will be monitored via discussions and plant revisits as appropriate.
An issue has been added to the ONR Regulatory Issues database for tracking purposes.