Sellafield – Regulating Cumbria’s giant

Mark Foy, Superintending Inspector on the Sellafield programme, explains how his team works to improve safety and reduce risk at the site.

Sellafield is one of the most talked about nuclear sites in the world; it is certainly one of the biggest comprising a wide range of nuclear facilities with high hazards and risks.  That is why, when most UK nuclear sites have one dedicated ONR inspector, the Cumbrian site has a whole team devoted to it. 

ONR has always placed a great deal of significance on Sellafield and when it started organising work into programmes in 2011, the regulation of the site became a programme in its own right.  A team of inspectors closely regulates all operations there and challenges the company responsible, Sellafield Ltd, to effectively manage and reduce its risks and hazards. 

Around 60 members of staff work on the Sellafield programme overseen by the Sellafield Intervention Management Group (IMG).  To ensure that we are able to target our effort appropriately, ONR has divided the programme into four sub?programmes covering Spent Fuel Management, Waste and Effluent Disposition, Decommissioning and Infrastructure.  Individual inspectors lead Intervention Progress Groups (IPGs) that are responsible for leading and coordinating our regulatory activities at Sellafield in each of these four areas, with the aim of ensuring people and society are protected from the nuclear and radiological hazards on the site. 

As well as continued day-to-day operational safety, the programme is focusing a great deal of effort on ensuring that the licensee delivers timely risk and hazard reduction, particularly in the Legacy Ponds and Silos area. It continues to be a challenge given the nature of the facilities concerned and requires close monitoring and oversight by our inspectors. 

We are also working to influence the licensee to deliver improvements in a number of areas across the site, and we have brigaded activities under four key themes: leadership and management, operational safety, engineering and safety cases.  These themes reflect where our own regulatory work and the licensee’s past performance have indicated a shortfall against the standards for nuclear safety & security performance expected of a mature licensee.  Our inspectors have engaged at the most senior levels within Sellafield’s organisation to align our desired outcomes and timescales with the licensee’s own programmes of work.

At the same time, we are working to ensure that we achieve ONR’s goal of programme working but recognise that we are only part way on the journey in ensuring a fully inclusive and integrated Sellafield programme of work.  Time and effort is being invested to make sure that safeguards, security and transport activities are recognised and incorporated into our future intervention plans.  We have also started work with the Environment Agency to ensure that, where appropriate, we integrate relevant aspects of its regulatory activities into our plans. 

This will be a significant year for Sellafield Ltd, who manage the site under contract to the Nuclear Decommissioning Authority (NDA).  We are satisfied that both are keen to see sustained improvements in nuclear safety, security, safeguards and waste management performance.  However, we still expect significant improvements in key areas and want to see delivery against commitments this year, whilst recognising that it will take several years to consolidate the required nuclear safety improvements across the site.

Wherever possible, ONR works with Sellafield Ltd to improve safety standards and reduce hazards and risks.  For example, last year ONR revised its strategy for regulatory control of Highly Active Liquor (HAL) stocks at Sellafield.  HAL is a necessary bi-product of reprocessing spent fuel and the revised strategy aims to ensure safe management of HAL stocks, helping to reduce them to the lowest practical level.  The revised Stocks Specification[1] will continue to drive very significant year-on-year reductions in the stocks of HAL, until the long term minimal working level is reached in 2015.  It will provide Sellafield with greater flexibility, enabling a quicker reduction of the total radioactive waste on site and across the UK.

Another example of where we have worked with the licensee to facilitate the delivery of major hazard and risk reduction is on a project to remove highly corroded, redundant pipework and improve the primary containment of the First Generation Magnox Storage Pond.  The project ran to tight timescales, but identifying a lead project inspector, allocating the required resource, setting clear regulatory expectation for each stage of the project and maintaining good communications ensured that we were able to support the licensee’s work, which has led to successful completion of the first phase of this high profile project.

More recently, Sellafield Ltd has improved its safety processes by including the Annual Review of Safety as an integral part of its routine business; no longer seen as something to satisfy the regulators need.  It will hold internal reviews every 4 months and a formal review involving ONR once a year.  The latter took place in December 2011 and was considered a vast improvement on previous years.  The revised approach should allow Sellafield to include identified improvements in the following year’s business plan. 

Whilst working closely with the licensee, we have not shied away from taking enforcement action where needed and inspectors have served a number of Improvement Notices on Sellafield Ltd in recent years in relation to adequate risk assessments, training of staff and the provision of safe systems of work.  We have also successfully prosecuted Sellafield Ltd twice in the recent past.  Within the last 18-months, we have also put in place fixed arrangements, via formal Approval under Licence Condition 35.  This will allow us sufficient control and oversight while facilitating delivery of the licensee’s decommissioning programmes.

These are only a few examples of the work ONR is doing to help make Sellafield safer and more secure.  However, there is a lot more to do such as improving emergency arrangements at the site and ensuring that the licensee is able to deliver its long-term Periodic Safety Review (PSR) commitments.  We also want to ensure that Sellafield is able to fulfil its own duties in relation to safe storage and conditioning of nuclear material on the site whilst serving the needs of national consolidation strategies.

Although we realise there is a long way to go, I am encouraged with the Executive now in place at Sellafield.  It is clear on its mission to improve nuclear safety and security performance and to deliver timely hazard, and risk reduction.  ONR, through the Sellafield programme, will continue to aim for the protection of people and society from the nuclear and radiological hazards at Sellafield.

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