The Office for Nuclear Regulation (ONR) undertakes all regulatory interactions with Sellafield Limited (SL, the site licensee) in line with a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste Programme. As part of this Strategy, ONR carries out Operating Readiness Inspections as it deems appropriate. These examine whether SL can demonstrate that the safety case and supporting implementation through its arrangements are adequate to support permissioning.
This intervention was undertaken between 11-12 October 2016, to examine the adequacy of SL's arrangements supporting permissioning of the First Generation Reprocessing Plant (FGRP) stack removal. A particular focus of this inspection was to evaluate the adequacy of human factors aspects of the proposed activities.
The findings of the intervention will be used to inform my human factors advice regarding the regulatory hold point to commencement of operations for FGRP stack removal.
The inspection focused upon a number of key human factors considerations identified as part of ONR's permissioning assessment of SL's safety case submission for removal of the FGRP stack. This included discussions with the primary contractor involved in the operations and key Sellafield staff, inspection of the task face and examination of supporting documents and arrangements.
In arriving at my conclusions concerning adequacy of the human factors aspects of the arrangements for stack removal I also considered the interventions I have undertaken with the FGRP project to date.
This inspection supports the Project Delivery Sub-programme, specifically Objective 3: ONR will undertake interventions to ensure delivery of activities that will reduce the risk profile in the decommissioning facilities at the Sellafield Site.
I have focused my inspection on the following factors that I consider to be key, from a human factors perspective to permissioning:
This inspection focuses upon examining evidence in support of the above and on how the supporting arrangements implement the safety case limits and conditions, for example through command and control and control and supervision.
I have inspected against LC22 (1) Modification or Experiment on Existing using the supporting Technical Inspection Guide, (TIG). This requires the Licensee to 'make and implements adequate arrangements to control any modification or experiment carried out on any part of the existing plant or processes which may affect safety'. The supporting TIG outlines the expectations with regard to implementation of the modification. From a human factors perspective the following are relevant; implementation of adequate training (SQEPs) and its assessment has been completed, Operating rules and or instructions updated and implemented, roles and responsibilities clear and implemented and control and supervision is adequate.
In coming to my judgement I have also used the human factors related Safety Assessment Principles and associated Technical Assessment Guides, as they represent Relevant Good Practice (RGP).
This is not a system based inspection; not applicable.
The inspection highlighted a significant shortfall in that whilst SL had undertaken a human factors assessment it was after the safety submission and was not yet available. I take confidence in that the findings to be reported match my own inspection findings.
I found operator interfaces to be generally well-designed, I noted one area were SL had demonstrated best practice in relation to understanding the duration of tasks to minimise time pressures. I believe the tasks are adequately supported by the operating sequence which is logical, undertaken in a step-wise way and supported by an appropriate level of peer to peer and independent checking. I am of the view that the tasks involved in operating the Self Climbing Platform (SCP) are relatively simple in nature, within the limits and capabilities of operators and so both achievable and feasible.
The approach taken to demonstrate competency assurance meets with the expectations of RGP. Training records showed few minor gaps and SL was able to demonstrate that a suitable plan was in place to address these and to mitigate the risks in the interim. I am content that personnel are demonstrably competent to undertake the activities.
I found the quality of the procedural controls to be generally adequate, providing confidence that the content and layout of the operating procedures provide suitable task support to operators. There was one exception; the procedures covering response to exceeding limits and conditions set by the safety case; the Lockdown Procedure. This lacked clarity regarding the implementation actions and the criteria to be used in the decision to move to a lock down state.
I consider the level of control and supervision set to be appropriate given both the conventional hazards and the emphasis on operator action in fault prevention. Training records and discussions give me confidence that these individuals can deliver this appropriately. In addition, I found clear accountabilities and responsibilities in the various organisations involved in operations.
SL provided good evidence regarding how task environmental conditions are managed to minimise the potential detrimental effect on operator performance. I identified a significant shortfall in the management of fatigue posed by proposed working hours specifically that a Fatigue Risk Assessment hadn't been completed.
I have rated the inspection as amber; this is to reflect the significance of the shortfalls that I have raised. My findings were shared with, and accepted by the licensee at a feedback session at the close of the inspection. As a result of the intervention, I have identified a number of actions that SL will need to confirm have been completed to inform ONR's permissioning decision. These relate to submission of a human factors assessment, improvements to the clarity of the lockdown procedure and related decision making criteria, clarity of fatigue management arrangements and improvements to the level of frontline oversight of the Contractor provided by SL. I note that Sellafield's Internal Regulator has agreed to track these issues during the planned internal readiness inspection and to inform ONR of issue resolution. I have raised a Regulatory Issue 4873 to monitor these actions to resolution.
Given the strategic importance of the removal of the FGRP stack, the associated potential nuclear consequences and the reliance on operators to undertake tasks reliably and safely, I make one further recommendation to the ONR Project Inspector; for ONR to introduce a programme of review/inspection of the conduct of the stack removal at appropriate intervals to monitor progress and to ensure that OPEX is appropriately incorporated.
I conclude that, subject to confirmation from SL internal regulator of satisfactory closure of the recommendations I have made, I have no objections from a human factors perspective to SL commencing removal of the FGRP stack.