Date(s) of inspection:
- March 2023
Aim of inspection
The aim of the inspection was to conduct a two-day inspection relating to training and instructions to persons on site including a compliance inspection of Licence Conditions (LC) 9 and 10 at the Magnox Ltd Corporate Centre.
Subject(s) of inspection
- LC 09 – Instructions to persons on the site – rating: Amber
- LC 10 – Training – rating: Green
Key findings, inspector’s opinions and reasons for judgement made
I carried out a two-day corporate inspection relating to training and instructions to persons on site.
I spoke to the Magnox Ltd Head of Talent, Learning and Development, supported by their team, in order to understand if they were suitably qualified and experienced to understand the requirements of a proportionate, systematic approach to training.
I continued my discussion with the Learning and Development (L&D) team to assess if a proportionate systematic approach to training had been applied to induction training to allow unescorted access to its nuclear sites. The current arrangements rely on completion of the “NSAN triple bar for existing sites course” and induction to the specific site by means of a “host-brief”. The L&D team were able to produce a learning needs analysis conducted in 2016 for the “host-brief” but were unable to demonstrate a learning needs analysis was currently in place, to articulate all the required training objectives for unescorted access. No evidence was presented at the inspection of an adequate assessment strategy for ensuring training objectives had been met or that arrangements were in place to conduct external and internal validation of training or independent audit. However, an induction programme was in development by the L&D team which could, if well-conceived and implemented, return Magnox Ltd to compliance with the requirements of LC9 and demonstrate adequate LC10 compliance for this element of training.
I spoke to the Magnox Ltd Head of Construction about further elements of induction training required to access construction areas on the site. There are potentially groups of contractors and staff on site who may not need to enter construction areas and therefore may not receive this further training, therefore credit could not be taken for the content of this course for all staff and contractors for LC9 instruction purposes.
At the conclusion of the meeting, feedback was presented to Magnox Ltd on the inspection ratings, observations and advice, with the Magnox Ltd EHSSQ Director present.
It is my opinion that any compliance shortfalls identified in relation to the systematic approach to training in accordance with ONR guidance for LC10 have already been self-identified by the competent Magnox Ltd Corporate Learning and Development team and although there are identified areas of improvement, these have an action plan to address them. Magnox Ltd should ensure there is sufficient SQEP resource to complete these plans. Therefore, in my opinion and due to the limited scope of the inspection, i.e., induction training, I am content to rate this element as green – “no formal action”, but without sustained effort this could fall below regulatory expectations.
From my inspection of LC9, I rated this as amber – “seek improvement” and raised a Level 3 ONR regulatory issue to ensure improvements and a proportionate systematic approach to training is applied by Magnox Ltd to induction training and that management arrangements are in place to confirm training objectives required to satisfy LC9 have been met for all persons with access to its nuclear sites. In accordance with the ONR enforcement policy statement this rating resulted in “regulatory advice” which has been given in feedback sessions from the inspection and is being tracked to adequate conclusion by a regulatory issue.