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 on Licence Condition (LC) 26 (Control and Supervision of Operations) at the Analytical Services Process Facility on 19 October 2017 as part of its follow-up on regulatory issue 3294. This regulatory issue concerns generic shortfalls ONR has found in SL's control and supervision of contractors.
The Analytical Services Process Facility was chosen for this inspection because contractors are currently working at the facility - on removal and replacement of a ventilation fan - and therefore it provided an opportunity for ONR to test SL's control and supervision arrangements. The inspection at the Analytical Services Process Facility is the second of two inspections ONR has undertaken to test SL's response to regulatory issue 3294 (see ONR-SDFW-IR-17-119 for the first report).
LC26 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 / Nominated Representatives on nuclear safety matters and the opportunity to improve coverage of nuclear safety in task risk assessments.
ONR's inspection of the Analytical Services Process Facility was carried out by the Corporate Inspector for Sellafield and comprised discussions with SL staff and the contractor's supervisors, sampling of records, and inspection of the work site. The inspection was carried out with reference to the following ONR inspection guidance:
Not applicable as this was not a system based inspection.
The activity I inspected at the Analytical Services Process Facility concerned removal and replacement of one of the large ventilation fans (Fan 5) in the building Heating, Ventilation and Air-Conditioning System using a mobile crane. I first examined the risk assessment for the work which comprised a task risk assessment and crane proposal form. I found that these documents adequately addressed the nuclear and radiological safety hazards associated with the work including the potential for crane collapse / dropped loads and contamination spread. I found the contractors supervisors to have a satisfactory awareness of these hazards and the controls in place. Specifically the contractors described the slew restrictions in place (to prevent a potential dropped load onto the building) and I also observed the temporary ‘C3' barrier which has been set up to control access to the fan. The supervision arrangements described by the contractors were in accordance with the statements in the risk assessment.
I found that there was good communication between SL staff, and between SL and the contractors, on the work being undertaken. For example, SL's Person Organising the Work (POW), together with the contractor's supervisors, provide daily briefs to the work team. The POW also checks progress at the end of each day and communicates this to the Duly Authorised Person (DAP) for the Analytical Services Process Facility and the Nominated Representatives. The Nominated Representatives hold weekly meetings with the POW to review the status of work and approve the list of tasks for the following week, which they then communicate to the contractor.
I found SL's Nominated Representatives to be knowledgeable in their roles responsibilities, accountabilities and authorities and to be exercising satisfactory control of the contractor's work in conjunction with the POW, DAP and Safe System Controller. The Nominated Representatives had received the necessary training and had been formally appointed by the Superintending Officer in accordance with SL's arrangements. They will receive additional training on nuclear safety culture as part of a broader initiative across the Sellafield site.
Overall I consider that SL's control and supervision arrangements were adequate for this work and commensurate with the nuclear safety hazard.
I consider that SL has adequately implemented its arrangements for control and supervision of contractors for the Fan 5 removal / replacement work at the Analytical Services Process Facility. Therefore, it is my opinion that an inspection rating of ‘Green' (No formal action) is merited.