- Site: Sellafield
- IR number: 22-044
- Date: July 2022
- LC numbers: 10, 12
Purpose of Intervention
The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Sellafield site licensee (Sellafield Ltd) against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. The planned inspection schedule for 2022/23, identifies the Licence Conditions (LCs) that will be inspected during this period.
The purpose of this inspection was for ONR to determine the adequacy of implementation of Sellafield Ltd’s arrangements for compliance with LC10 (Training) and LC12 (Duly authorised and other suitably qualified and experiences persons) at the Spent Fuel Services (SFS) operating unit.
The overall adequacy of Sellafield Ltd’s site-wide LC10 and LC12 arrangements is considered separately in other ONR interventions.
In carrying out this inspection, the following ONR guidance was used:
- ONR-INSP-GD-059 Revision 8 Guidance for Inspection Strategy Planning and Recording;
- ONR-INSP-GD-010 Revision 3 Nuclear Safety Technical Inspection Guide Licence Condition 10 – Training
- NS-INSP-GD-012 Revision 3 Nuclear Safety Technical Inspection Guide Licence Condition 12 – Duly authorised and other suitably qualified and experienced persons
Interventions Carried Out by ONR
The inspection focused on the following areas:
- Training team capability;
- Training governance;
- The status of training courses;
- Training status of SFS staff; and
- A check of the qualification status against the Fuel Storage (South) Minimum Safe Manning Levels document.
- Duly Appointed Persons (DAP) status for the shift on duty at the time of the intervention;
- Appointed Suitably Qualified and Experience Person (ASQEP) status for the shift on duty at the time of the intervention; and
- SQEP status for a sample task for the shift on duty at the time of the intervention.
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
We found the SFS Training Lead has a good understanding of the training status at the operating unit; dashboards were provided showing the training status, as was evidence of training governance meetings being undertaken. Staff on roster on the date of the intervention were qualified and had been formally appointed for both duly authorised and appointed suitably qualified and experienced persons roles. A sample check showed that other personnel were trained for their roles, including minimum safe manning level requirements. Personnel undertaking a key activity (caustic dosing) at the time of the intervention were qualified.
We found that SQEP periodic reviews at SFS are short of the Sellafield target, but not by a significant amount.
SFS has undertaken a mapping exercise of all legacy training packs and concluded that they are fit for purpose for initial and continuation training, but we found that around 25% are overdue their formal periodic review. We are satisfied that the mapping exercise provides assurance that the training is sufficient to maintain safe nuclear operations but have raised a Level 4 (i.e.; lowest level) regulatory issue to monitor progress with the formal review of training packs.
SFS is supported by a training lead who also covers Magnox Reprocessing, two training coordinators and two training developers. It has been recognised by Sellafield Limited that SFS needs a dedicated training lead and the process to split the role is on-going. It was also recognised by SFS that the training developers will need support to cover the backlog in legacy training and the anticipated demand caused by planned plant changes.
Overall, we are satisfied with SFS’s implementation of the corporate arrangements for LC 10 and LC 12.
Conclusion of Intervention
On the basis of the evidence sampled at the time of the inspection, we judge that the dutyholder has adequately implemented the licensee’s corporate arrangements for LCs 10 and 12, with one minor area for improvement identified. One Level 4 (i.e.; lowest level) regulatory issue has been raised to manage the implementation of the identified area for improvement.
Taking the above findings into account, and noting the ONR guidance on inspection ratings, we judge that Sellafield Limited has adequately implemented its arrangements for compliance with LCs 10 and 12 at SFS. We therefore consider that an inspection rating of Green (No Formal Action) is merited.