The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Sellafield site licensee (Sellafield Ltd, SL) against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste Division. In accordance with this strategy, ONR carried out an inspection at the Windscale Advanced Gas Cooled Reactor (WAGR) Intermediate Level Waste (ILW) facility on 12 September 2017 as part of its follow-up on regulatory issue 3294. This regulatory issues concerns generic shortfalls ONR has found in SL's control and supervision of contractors.
The WAGR ILW facility was chosen for this inspection because contractors are currently working at the facility - on scaffold erection - and therefore it provided an opportunity for ONR to test SL's control and supervision arrangements. The inspection at the WAGR ILW Facility is one of two inspections ONR will undertake to test SL's response to regulatory issue 3294.
Licence Condition (LC) 26 requires the licensee to ensure that no operations are carried out which may affect safety except under the control and supervision of suitably qualified and experienced persons appointed for that purpose by the licensee. This includes operations carried out by contractors.
Regulatory issue 3294 concerns generic shortfalls ONR has identified in SL's control and supervision of contractors, in particular relating to the competence of Superintending Officers on nuclear safety matters and the opportunity to improve coverage of nuclear safety in task risk assessments.
ONR's inspection of the WAGR ILW facility was carried out by the Corporate Inspector for Sellafield and comprised discussions with SL staff and the contractor's supervisor, sampling of records, and inspection of the work site. The inspection was carried out with reference to the following ONR inspection guidance:
'LC26 Control and Supervision of Operations', NS-INSP-GD-026, Revision 3, March 2016.
Not applicable as this was not a system based inspection.
I examined the competence requirements and training record of SL's Superintending Officer (SO) for the contract under which the work at the WAGR ILW Facility was being undertaken. I found the training for the SO to be sufficient and up-to-date against the requirements set by SL for this work. I verified the SO's written appointment for this contract as required by SL's arrangements. I found the SO to be knowledgeable in his role, responsibilities, accountability and authority, including interface with the Duly Authorised Person (DAP) on nuclear safety matters. The SO has not received any specific training in relation to nuclear safety however, subsequent to this inspection, the Head of the Contractors Management Department advised me that he will require all SOs to undertake SL's recently-developed nuclear safety culture e-learning. I consider this an appropriate level of training given that command and control of nuclear safety rests primarily with the DAP (including for contracted work) with the SO providing a complementary role and the main point of contact for the contractor.
The work being undertaken at the WAGR ILW Facility on 12 September 2017 concerned erection of scaffolding to enable cladding and soffit repairs on the exterior of the building. The work excluded the building repairs themselves. In this context I was content that the risk assessment for the work did not identify any specific nuclear safety hazards associated with the scaffold build. The means of control of the work - via an Approved Scheme of Work - was appropriate with approval by the Safe Systems of Work Controller (SSC), as per SL's arrangements. I examined two of the control measures specified in the risk assessment and verified that these were being implemented by the contractor. In examining the risk assessment I observed a change in the scope of work to include an activity inside the building. This followed SL's due process in that the risk assessment was revised to include the new hazard (radiation) and associated control measures, and was re-approved by the SSC and safety adviser. However I consider that the change should have been considered at a higher level given that it affected the basis on which the authorisation for the scaffolding work was originally given. I advised SL accordingly and I am content to leave this with SL to progress.
Overall I consider that SL's control and supervision arrangements were adequate for this work and commensurate with the nuclear safety hazard. I noted two minor weaknesses concerning the specification of control and supervisory arrangements in the risk assessment and independent acceptance of the risk assessment by the SO or Nominated Representative (NR). I also drew these to the attention of SL.
On balance, from the evidence sampled during this inspection, I consider that SL has adequately implemented its arrangements for control and supervision of contractors at the WAGR ILW facility, with minor shortfalls identified when compared with appropriate benchmarks. Therefore, it is my opinion that an inspection rating of 'Green' (No formal action) is merited.