Office for Nuclear Regulation

Review of work undertaken to address Improvement Notice IN-19-001 and Enforcement letters

Executive summary

Purpose of Intervention

The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Sellafield site licensee (Sellafield Limited, SL) against a strategy defined by the ONR Sellafield Sub Division. In accordance with that strategy, Licence Condition (LC) compliance inspections were carried out within the Spent Fuel Management (SFM) value stream in February 2020. 

Interventions Carried Out by ONR

On 6 February 2020, I, the site inspector for the operational waste facilities, carried out a review of the work undertaken by SL to address Improvement Notice IN-19-001 and Enforcement Letters EL-19-001 and EL-19-018, following events which occurred on 07 February 2019 and 25 September 2019 within the Waste Vitrification Plant (WVP).

Explanation of Judgement if Safety System Not Judged to be Adequate

This was not a system based inspection, and therefore no judgement has been made of the adequacy of implementation of any part of the safety case.

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

I reviewed the evidence of the work undertaken to address the shortfalls identified in the Improvement Notice and enforcement letters.

I sampled the revised training programme descriptions and job training profiles and judge that an adequate structured approach has been undertaken to define the competency requirements and training programme for members of the container handling and waste team.

I reviewed the approach taken to assess the competence of the members of the container handling and waste team and sampled the duly authorised person and team leader appointments.  On the basis of the evidence provided I judge that an adequate assessment of the competence of each member of the container handling team and waste team has been taken against the competency requirements in this area.

  I also reviewed the minutes of the procedural workshops and sampled a revised instruction that was not followed during the previous event which led to the Improvement Notice.  I compared the original revision to the latest version and could clearly see the improvements made.  I judge that a suitable and sufficient review and revision of the container handling and waste team operating instructions has been undertaken and is commensurate with the safety case requirements.

I noted that the container document wallets are now held by the team leaders under lock and key and only issued during task allocation.  I also noted that in addition to the safety stand down and briefings, manager in the field and shift team co-ordinator audits were enacted immediately to enhance procedural use and adherence. In order to sustain this going forward the head of operations has restructured the organisation the align DAPs and operators to the operations manager who is responsible for facility standards.

I judge that suitable and sufficient measures have been put in place to ensure that all container handling and waste operations which may affect safety are carried out in accordance with the operating instructions.

The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.

Conclusion of Intervention

From the evidence gathered during this intervention, I am satisfied that the work undertaken by SL has addressed the contraventions of LC10(1), LC12(1), LC24(1) and LC26 and satisfied the requirements of Improvement Notice IN-19-001 and Enforcement Letters EL-19-001 and EL-19-018.  ONR will continue to monitor role out of this approach across the rest of the facility as part of routine business.

I consider that the required standard has now been met for LC10, LC12, LC24 and LC26 and inspection ratings of Green (No Formal Action) is merited for these licence conditions.

At present, no additional regulatory action is needed over and above the planned interventions within Spent Fuel Management value stream at the Sellafield Nuclear Site as set out in the Integrated Intervention Strategy, which will continue as planned.