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 (SDFW) Programme. The 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 (the Directorate) is adequately implementing SL's site-wide arrangements for compliance with Licence Condition 9 (instructions to persons on site), focussed on the provision of induction training for site staff, contractors and visitors to the First Generation Magnox Storage Pond (FGMSP) and associated facilities. FGMSP was selected because it is one of the most hazardous facilities on the Sellafield site and because waste retrieval operations are now taking place which require an increase in personnel working there. It is important that all personnel working on FGMSP facilities receive adequate instruction regarding the risks and hazards associated with FGMSP, the precautions to be observed and the actions to take in the event of an accident or emergency in order to ensure their safety.
This inspection has targeted the implementation of SL's site-wide arrangements for Licence Condition 9 by the Directorate and FGMSP. The adequacy of SL's site-wide arrangements more generally is considered in other inspections.
Licence Condition 9 (LC 9) requires the licensee to ensure that every person authorised to be on the Sellafield site receives adequate instructions as regards the risks and hazards associated with the plant and its operation, the precautions to be observed in connection therewith and the action to be taken in the event of an accident or emergency on the site.
My inspection, which comprised discussions with SL staff and examination of Directorate and FGMSP plant documentation, focussed on the following areas:
Not applicable; this was not a Safety System inspection.
From my inspection findings, I consider the implementation of the licensee's arrangements for LC 9 within the Directorate and FGMSP is good in some areas. For instance, there was good evidence of the induction process itself and the importance it is given. This was exemplified by the induction arrangements for contractors and the quality of the evidence I saw showing how the required induction training is identified, completed and recorded.
This is however, offset by a number of shortfalls. In particular, SL needs to review and update the content of the Directorate and SPP1 (Sludge Packaging Plant 1) induction training material. Specifically, the training material needs to comply with the site arrangements and identify all the risks and hazards associated with working in the Directorate and at the SPP1 facility, and the operations carried out in these locations. This should also include the precautions to be observed and the actions to be taken in the event of an accident or emergency. SL needs also to ensure that in its recently initiated updates to this induction training material, it removes the minor inconsistencies noted in this inspection.
On balance, in view of the shortfalls observed, I consider an Inspection rating of Amber (Seek Improvement) is merited against LC 9 as a result of this inspection.
My findings were shared with, and accepted by, the licensee as part of normal inspection feedback. I have raised a new Regulatory Issue as a result of this inspection. This relates to the need for SL to review and update its Directorate and SPP1 induction training material to comply with the site's arrangements and to remove minor inconsistencies. Other matters noted during this inspection will be tracked as part of routine regulatory business.