- Site: Sellafield
- IR number: 22-031
- Date: June 2022
- LC numbers: 10
Purpose of Intervention
In accordance with the Office for Nuclear Regulation’s (ONR’s) Sellafield Strategy, each year ONR performs a series of planned compliance inspections of selected licence conditions, targeted at those facilities with significant importance to nuclear safety.
The purpose of this inspection is to seek assurance that the National Nuclear Laboratory (NNL) implementation of the Sellafield Limited arrangements is in compliance with Licence Condition (LC) 10 within the Active Handling Facility (AHF) on the Sellafield site. The inspection also allows ONR to test the effectiveness of the changes made in NNL’s training arrangements following INF-1218 and relating to the open Regulatory Issue RI 10443.
Interventions Carried Out by ONR
The inspection of LC10 compliance at the AHF was undertaken on the 8th June 2022 by the ONR Site Inspector and the Human Factors Specialist Inspector.
The inspection sought evidence of compliance with the LC10 training arrangements, and also assurance of effectiveness of the changes made in NNL’s training arrangements following INF-1218. This was achieved through a remote inspection (i.e. not physically attending the Sellafield site) involving a combination of reviewing documentary evidence, sampling records, discussion with the training team and interviewing DAP, Task Supervisors, process workers and contractor supervisor.
LC10 requires the licensee to make and implement adequate arrangements for suitable training for all those on site who have responsibility for any operations which may affect safety.
The following ONR guidance was used as a basis of regulatory expectations for the inspections:
- Technical Inspection Guide, LC10 Training, NS-INSP-GD-010, Revision 3
Explanation of Judgement if Safety System Not Judged to be Adequate
This was not a system-based inspection.
Key Findings, Inspector’s Opinions and Reasons for Judgements Made
NNL presented its local LC10 arrangements, its implementation of the Systematic Approach to Training (SAT) and the structure of the training arrangements. I consider that NNL’s training arrangements are in line with relevant good practice and are fit for purpose.
I consider the new training course identified following incident reference INF-1218 – Safety Case required Operating Instruction (rOI) compliance, that has been designed and launched by the NNL safety case team, to be a positive step forward to improving its training arrangements.
I consider the changes to the SQEP assessment process following INF-1218, effective in enhancing safety case understanding of the workforce and appreciation of the importance of compliance. I consider it an improvement that should lead to disciplined operations and better rOI compliance.
Through the interviews with the DAP, task supervisors, process workers and contractor supervisor, I have gained assurance that the changes in NNL’s training arrangements are timely and effective in enhancing SQEPness which, in the longerterm, should benefit safe operations in AHF.
Based on the evidence sampled as part of this inspection, I judge that the required standard is met and an inspection rating of Green (no formal action) was appropriate against LC10.
Conclusion of Intervention
Taking the above key findings into consideration, and noting the ONR guidance on inspection ratings, I judge that the licensee has adequately implemented its arrangements for compliance with LC10 at the AHF. I therefore consider that an inspection rating of Green (No Formal Action) is merited.