Date(s) of inspection:
- October 2023
Aim of inspection
In accordance with the Office for Nuclear Regulation’s (ONR’s) Sellafield Strategy, each year ONR performs a series of planned inspections to seek assurance of compliance against selected licence conditions, targeted at those facilities with significant importance to nuclear safety. One such inspection was undertaken at Special Nuclear Materials (SNM) North facilities within the Sellafield site in West Cumbria to sample evidence of implementation of Sellafield Limited’s arrangements for compliance with Licence Condition (LC) 12 and LC26 in order to inform a regulatory judgement regarding the licensee’s compliance with its legal duties under the nuclear site licence.
Subject(s) of inspection
- LC12 – Duly authorised and other suitably qualified and experienced persons – Rating: Green
- LC26 – Control and supervision of operations – Rating: Green
Key findings, inspector’s opinions and reasons for judgement made
The inspection was undertaken on 11 and 12 October 2023 by the SNM site inspector and a human factors specialist inspector. The inspection targeted compliance against Licence Condition (LC) 12 (Duly authorised and other suitably qualified and experienced persons) and LC26 (Control and supervision of operations).
The inspection involved a planning phase and a site visit, which included discussions with relevant Sellafield Limited personnel, review of records, and sampling of information contained within electronic databases and other documentation, and plant visits.
For LC12, I focused on Duly Authorised Person (DAP) and Appointed Suitably Qualified and Experienced Personnel (ASQEP) competency assessments, letters of appointment, and DAP shift handover and records. I identified no significant shortfalls requiring regulatory attention. With the exception of the Operations ASQEP, I found that suitably qualified and experienced personnel had been appointed. I judged it proportionate to raise a Level 4 Regulatory Issue (RI 11734) to ensure the formal appointment of all Operations ASQEPs is achieved in a timely manner. On plant I noted adequate handover between the off-going and oncoming DAPs, which was supported by appropriate records.
For LC26, I focused on Control and Supervision Organisation Baseline, the Minimum Safe Manning Level (MSML), Operational and Conservative Decision Making (ODM/ CDM), and observed the daily Plant Operational Control Centre (POCC) and the control and supervision of an activity. I identified no significant shortfalls requiring regulatory attention. I found that the DAP was effectively controlling and supervising the daily operations. During the plant visit, I also found an adequate level of control and supervision of the Operations ASQEP by the DAP.
Whilst the Control and Supervision Baseline and MSML were approved by the Management Safety Committee (MSC), I found that MSML hasn’t been updated to incorporate the changes of the Management of Change Risk Assessment (MoCRA 8306), due to lack of SQEP authors. I judged it appropriate to raise a Level 4 Regulatory Issue (RI 11735) to ensure the review and update of the MSML document is completed in a timely manner.
I sampled a number of open ODM/ CDM and noted that a number have been open for years, which is not in line with the corporate arrangements. I therefore judged it appropriate to raise a Level 4 Regulatory Issue (RI 11736) to ensure all ODM and CDMs are progressed and closed in a timely manner.
On the basis of evidence sampled and the interactions that I held with Sellafield Limited staff, at the time of the inspection, I judge that, on balance, Sellafield Limited has largely implemented its arrangements for compliance with LC12 (Duly authorised and other suitably qualified and experienced persons) and LC26 (Control and supervision of operations). Upon consideration of the ONR guidance on inspection ratings, I judge that a rating of green (no formal action) is appropriate.
I have identified three minor shortfalls and I have raised three Level 4 (lowest level) Regulatory Issues to track resolution of these shortfalls.