Office for Nuclear Regulation

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Sellafield - Planned Licence Condition Inspection of Thorp and Early Engagement on Decommissioning Projects

Executive summary

Purpose of intervention

The purpose of this inspection was to undertake early engagement with regard to Human Factors (HF) aspects of a number of decommissioning projects and to undertake a Licence Condition (LC) compliance inspection of the Thorp facility in line with our planned inspection programme.

Interventions Carried Out by ONR

As part of this intervention, I undertook information exchange and examination meetings relating to the following projects:

I also undertook a planned compliance inspection of Licence Condition 36; Organisational Capability at the Thorp Facility in line with the planned inspection programme and followed up previous inspection findings on management of resource capability, fatigue management and trialling of 12 hour shifts.

Explanation of Judgement if Safety System Not Judged to be Adequate

There was no safety system inspection carried out during this intervention

Key Findings, Inspector's Opinions and Reasons for Judgements Made

With regard to the Human Factors aspects associated with export and transport of residues from Finishing Line 3, I found that a structured approach had been taken to the task design and found good evidence of learning from experience. I also noted a considered approach to work organisation and commitment to employ a systematic approach to training. This gives confidence in the task design and feasibility of the operator tasks. Whilst welcoming these positive aspects, I found less clarity on the scope and coverage of the upcoming trials. It is important that a structured and rigorous approach is taken within the trials and that this covers aspects such as work station set up, routine tasks, task and error recovery, testing of work instructions, operator assumptions, and key operator claims This is important to ensure that the work will be completed right first time and to a high standard. I have emphasised the need for a structured and rigorous approach to the trials to the Licensee and will follow this up as part of my visit to observe the trials and inform the ONR readiness review.

First Generation Magnox Storage Pond Additional Sludge Retrievals Project - this early engagement helped clarify the nature of Human Factors issues associated with the project and set out ONR expectations in this area. I found that there are a number of important HF issues associated with the project and that a structured and targeted approach to HF would be required to meet the aggressive timescales proposed and support a right first time' approach. From the discussion at the meeting, it appears that this is not yet fully in place, and I will be following this up as part ongoing engagement. In particular, the Licensee should give consideration to identifying the nature of key supporting HF activities and how these will inform and integrate with the wider project to support effective and reliable human performance.

First Generation Magnox Storage Pond Second Skip Handler Capability Project - overall this was a positive meeting. I found evidence of learning from experience in relation to the existing skip handling machine and it is clear that this has fed into the development of the design for the second skip handler. It was also evident that consideration has been given to Human Factors issues within the upcoming detailed design stage and I found the Human Factors Intelligent Customer scoping document identifies an appropriate set of activities to be specified and monitored. I consider that further information is required in relation to the use of contractors for the Intelligent Customer role and I will follow this and other identified issues up as part of future engagement. As the work develops I note that it will be beneficial to request a copy of the Human Factors Integration Plan which will be developed as part of the 'Tendered Work Package. This will provide an early route map of how human factors issues are being addressed to enable us to develop confidence in the Licensee approach.

Organisational Capability Inspection - from the evidence presented during the inspection, the IIS rating assigned to LC 36 is 3 (adequate). This is because whilst there are inconsistencies in application of Management of Change procedures, THORP was able to demonstrate a structured approach and I did not identify any significant shortfalls in its application. In terms of resource capability, whilst there are opportunities to improve the clarity of arrangements for utilisation and arranging cover, I found that THORP has made significant progress in reducing breaches of the minimum safety manning levels for the central control room operators. I also noted that the trials for 12hr working are being well-managed and the results indicate that this initiative will contribute to the resolution of resource problems in this safety significant area of the plant.

Conclusion of Intervention

Based on the findings from this sampling inspection, I judge Sellafield Ltd to be compliant with its arrangements under LC 36, justifying a rating of 3 - Adequate.

From examination of the evidence presented as part of early engagement on decommissioning projects, no significant shortfalls were identified. Where limitations have been identified these have been identified to the relevant project leads and will be taken forward as part of routine regulatory engagement.

There are no findings from this inspection that could significantly undermine nuclear safety.