- Site: Sellafield
- IR number: 22-042
- Date: June 2022
- LC numbers: 10, 12, 24, 26
Purpose of Intervention
The Office for Nuclear Regulation (ONR) undertakes all regulatory interactions with the Sellafield site licensee (Sellafield Limited) against a strategy defined by the ONR Sellafield subdivision. In accordance with this strategy, a planned Licence Condition (LC) compliance inspection was carried out at the Waste Treatment Complex (WTC).
The purpose of this inspection was to confirm that Sellafield Limited is adequately implementing its arrangements for LC10 (Training), 12 (Duly authorised and other suitably qualified and experienced persons), 24 (Operating instructions) and 26 (Control and supervision of operations) at WTC.
Interventions Carried Out by ONR
The inspection was a planned LC10, 12, 24 and 26 intervention conducted at WTC and was undertaken on 5 – 7 July 2022 by the ONR Site Inspector for Remediation, two Leadership and Management for Safety (LMfS) Specialist Inspectors and a Chemistry Specialist Inspector. The inspection comprised discussions with Sellafield Limited personnel, the observation of key meetings related to the control of operations, a review of a targeted sample of Sellafield Limited’s documentation and a plant walkdown. A representative of Sellafield Limited’s Nuclear Intelligence and Independent Oversight (NI&IO) function also participated.
LC10(1) 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.
LC12(1) requires the licensee to make and implement adequate arrangements to ensure that only suitably qualified and experienced persons (SQEPs) perform any duties which may affect the safety of operations on the site, or any other duties assigned by or under these conditions or any arrangements required under these conditions.
LC12(2) provides for the appointment, in appropriate cases, of duly authorised persons (DAPs) to control and supervise operations which may affect plant safety.
LC24(1) requires the licensee to ensure that all operations which may affect safety are carried out in accordance with written instructions. LC24(2) requires the licensee to ensure that such operating instructions include any operating instructions necessary to ensure that any operating rules are implemented.
LC26 requires the licensee to ensure no operations are carried out which may affect safety, except under the control and supervision of SQEPs appointed for that purpose by the licensee.
As part of the preparation for the delivery of this intervention, the following formal ONR guidance documentation was used:
- NS-INSP-GD-010 “Licence Condition 10 – Training;
- NS-INSP-GD-012 “Licence Condition 12 – Duly Authorised and Other Suitably Qualified and Experienced Persons;
- NS-INSP-GD-024 “Licence Condition 24 – Operating Instructions; and
- NS-INSP-GD-026 “Licence Condition 26 – Control and Supervision of Operations.
The scope and priorities of the inspection took into account intelligence gained from other ONR interventions.
Explanation of Judgement if Safety System Not Judged to be Adequate
Not applicable, as this was not a System Based Inspection.
Key Findings, Inspector’s Opinions and Reasons for Judgements Made
For LC10, we identified no shortfalls requiring regulatory attention. WTC has met the Sellafield Limited site target of 95% complete annual SQEP periodic reviews, which demonstrated suitable progress in this site-wide improvement initiative.
For LC12, we identified no shortfalls requiring regulatory attention. We observed effective collaboration between the Sellafield Limited off-going and oncoming DAPs and Appointed SQEPs (ASQEPs) during plant handovers, which were supported by appropriate records. We found evidence that SQEPs had been duly appointed. We provided regulatory advice in relation to minor administrative errors associated with the DAP and ASQEP records. We judged that this did not warrant raising any Regulatory Issues.
For LC24, we identified no shortfalls requiring regulatory attention. Overall, the quality of procedures sampled was judged to be adequate. There was a minor observation noted in relation to the inconsistency in the record retention period for procedures. We judged that this minor regulatory observations did not warrant raising any Regulatory Issues.
For LC26, we identified no shortfalls requiring regulatory attention. We found that SQEP personnel had been appointed and were effectively controlling and supervising operations. We provided further regulatory advice regarding some minor areas for improvement and encouraged Sellafield Limited to incorporate them into its Conduct of Operations Improvement Programme, as appropriate.
We found some limited evidence of weaknesses in records management which may indicate a shortfall in compliance with LC 6 (Documents, records, authorities and certificates). We therefore intend to schedule a future intervention specifically targeting compliance in WTC with the licensee’s arrangements for compliance with LC6. This will be followed up by the relevant ONR site inspector for remediation.
We provided regulatory advice on the safety leadership behaviours which we observed during the inspection. The purpose of providing this independent advice is to influence improvements in safety leadership and culture. Our advice was structured upon the SAFER Leadership Model as outlined in ONR’s recently published Safety Leadership Technical Assessment Guide. Our observations did not influence our inspection ratings.
Conclusion of Intervention
Taking the above key findings into account, and noting the ONR guidance on inspection ratings, we judge that Sellafield Limited has adequately implemented its arrangements for compliance with LC10 (Training), LC12 (Duly authorised and other suitably qualified and experienced persons), LC24 (Operating instructions) and LC 26 (Control and supervision of operations) at WTC. We therefore consider that an inspection rating of Green (No Formal Action) for each of the licence conditions targeted is merited.