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, Decommissioning, Fuel and Waste (SDFW) Division. As part of this strategy, a remote compliance inspection was undertaken to inspect the arrangements for the SL Office of the Consigning Authority (OCA). The OCA is responsible for ensuring that SL consigns nuclear transport packages safely from the Sellafield site. The inspection was conducted against the relevant ONR guidance:
This intervention was held remotely via teleconference with the SL OCA to inspect their procedural arrangements for compliance against the Carriage of Dangerous Goods Regulations 2009 (CDG).
The remote inspection involved consideration of the existing arrangements, discussion and presentation of ONR findings, and SL’s subsequent response.
The SL Management System (SLMS) is currently being reviewed and updated to reduce the overall number of documents and bring the procedures up to modern standards. At the time of the inspection only the transport high level document (Transport Mandatory Standard) has been updated with the remainder of the transport documentation yet to be reviewed and updated.
The current arrangements for the OCA are dispersed amongst numerous procedures, forms and check lists, each one dealing with a specific part of the transport process. As a result, there is a lack of clarity in relation to the overall process due to the large number of separate documents. In addition, the current procedures do not include an adequate definition of the key posts, roles and responsibilities involved. SL confirmed that it is their intention to address these shortfalls as part of the review and update of the SLMS in relation to transport.
The training records of the staff sampled were not held in a unified manner, however, sufficient evidence was provided to demonstrate suitable training was in place. Notwithstanding this, Sellafield Limited were unable to provide evidence that the training covered the entirety of the required scope nor where they able to provide evidence that they held sufficient information of external courses individuals had attended.
Sellafield Limited recognised the shortfalls identified in this inspection and the need to complete its review and update of the Transport arrangements and are prioritising this work appropriately. ONR considers that the shortfalls identified are, presently, not a significant safety risk due to the highly experienced staff in the Office of the Consignment Authority.
Noting the ONR guidance on inspection ratings, it is my opinion that an inspection rating of Amber (Below Standard) is merited. A Level 3 regulatory issue is to be raised for SL to address the regulatory shortfall associated with the transport arrangements and a Level 4 issue (the lowest level) is to be raised to address the minor shortfalls with training.