- Site: Sellafield
- IR number: 21-095
- Date: September 2021
- LC numbers: 10, 12, 24, 26
Executive summary
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 Licence Condition (LC) compliance inspections were carried out on the Miscellaneous Beta Gamma Waste Store (MBGWS), as planned.
The purpose of this inspection was to confirm that Sellafield Limited adequately implemented the 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 MBGWS.
Interventions Carried Out by ONR
The inspection was a planned LC10, 12, 24 and 26 inspection at MBGWS and was undertaken on the 28 and 29 September 2021 by the ONR Site Inspector for the Remediation Value Stream, a Leadership and Management for Safety Specialist Inspector and a Chemistry Specialist Inspector. The inspection comprised discussions with Sellafield Limited staff, reviews of a targeted sample of Sellafield Limited’s documentation and a plant visit. A representative of Sellafield Limited’s Nuclear Intelligence & Independent Oversight (NI&IO) function also participated.
LC10 requires Sellafield Limited 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 requires Sellafield Limited to make and implement adequate arrangements to ensure that only suitably qualified and experienced persons 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.
LC24 requires Sellafield Limited to ensure that all operations which may affect safety are carried out in accordance with written instructions.
LC26 requires the licensee to ensure no operations are carried out which may affect safety except under the control and supervision of suitably qualified and experienced persons appointed for that purpose.
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. We noted minor observations related to Sellafield Limited’s progress against its SQEP Improvement Plan at MBGWS and its programme to review legacy training materials at MBGWS.
For LC12, we identified no shortfalls requiring regulatory attention. We noted a minor observation where Sellafield Limited had misplaced a DAP appointment record, which was resolved during the inspection. We noted that Sellafield Limited has introduced a combined Operations DAP and Maintenance Authorised Suitably Qualified and Experienced Personnel (ASQEP) handover meeting in MBGWS, which is considered to represent good practice.
For LC24, we identified no shortfalls requiring regulatory attention. We noted a minor observation related to Sellafield Limited applying the ‘waiver process’ when Technical Authors have been involved in the design of a training package to ensure the records accurately reflect the knowledge of the personnel. We noted a good practice associated with the collaboration between the LC24 Process Lead, Technical Author, Plant management and the DAP community, and others for the recently updated Pilot Category 1 Operating Instruction.
For LC26, we identified no shortfalls requiring regulatory attention. We noted a minor observation associated with the consistent use of three-way communications. We noted the following good practices: the use of the phonetic alphabet, where appropriate, in the Plant Operations Control Centre (POCC) meeting; and application of a Major Breakdown Board and associated Fault Record Sheet used by maintenance personnel.
On balance, we were of the opinion that the regulatory observations noted above do not warrant raising any Regulatory Issues.
The NI&IO participant was content with the outcomes of this inspection. Our findings were shared with, acknowledged and accepted by the Sellafield Limited staff involved in the inspection.
Conclusion of Intervention
Taking the above key findings into account, and noting the ONR guidance on inspection ratings, we judge that the licensee has adequately implemented its arrangements for compliance with Licence Condition 10 (Training), Licence Condition 12, Licence Condition 24 (Operating Instructions) and Licence Condition 26 (Control and Supervision) in MBGWS. We therefore consider that an inspection rating of Green (No Formal Action) for each of the Licence Conditions (10, 12, 24 and 26) is merited.