- Site: Sellafield
- IR number: 21-103
- Date: October 2021
- LC numbers: 10, 12, 24, 26
Executive summary
Purpose of Intervention
The Office for Nuclear Regulation (ONR) undertakes all its regulatory interactions with the Sellafield Site licensee (Sellafield Limited), against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division.
In accordance with this strategy, a planned disciplined operations inspection was conducted at the Magnox Swarf Storage Silo (MSSS) on 5-7 October 2021. LC10 (Training), LC12 (Duly authorised and other suitably qualified and experienced persons), LC24 (Operating instructions) and LC26 (Control and supervision of operations) were targeted.
The purpose of this inspection was to judge the adequacy of the implementation of Sellafield Limited’s arrangements for compliance with LCs 10, 12, 24 and 26. The inspection also sought to inform a judgement on the MSSS facility’s progress against improvement programmes led by the corporate centre, which seek to address multiple corporate regulatory issues (RIs) pertaining to disciplined operations.
The inspection comprised of discussions with Sellafield Limited staff, review of a sample of Sellafield Limited records and other documentation, and a plant visit to the MSSS facility. The scope and priorities of the inspection considered intelligence gained from other ONR interventions.
Interventions Carried Out by ONR
The inspection was undertaken on 5, 6 and 7 October 2021 by a team consisting of the ONR site inspector for the Sellafield Limited Retrievals Value Stream, a Leadership and Management for Safety Specialist Inspector (Inspection lead), a Chemistry Specialist Inspector, a Human Factors Specialist Inspector and a Human Factors Nuclear Associate. A representative of Sellafield Limited’s Nuclear Intelligence & Independent Oversight (NI&IO) function and a Sellafield Limited Safety Representative also supported in the inspection.
The ONR team examined evidence to determine compliance against the following four licence conditions:
- 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 (SQEP) 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 SQEPs appointed for that purpose.
In carrying out this inspection, the following formal ONR guidance 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”;
- NS-INSP-GD-026 “Licence Condition 26 - Control and Supervision of Operations”;
- NS-TAST-GD-027 “Training and Assuring Personnel Competence”;
- NS-TAST-GD-060 “Procedure Design and Administrative Controls”.
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
I considered that the engagement prior to and during the inspection allowed for a meaningful inspection of compliance with the corporate arrangements for Licence Conditions 10, 12, 24 and 26, and all the inspection objectives were met.
For LC10, I identified no shortfalls requiring regulatory attention. I noted the minor observation that progress with the shortfall in respect of SQEP periodic reviews should be accelerated to ensure the agreed timescales for RI 8933 (level 4) closure are met. I identified that on-the-job training packs clearly link to the related operating instructions and safety case requirements, which is considered to be good practice.
For LC12, I identified no shortfalls requiring regulatory attention. I noted the good practice of Sellafield Limited’s effective application of Tier 1 assurance (self-assurance) to identify and correct issues ahead of the inspection.
For LC24, I identified no shortfalls requiring regulatory attention. I noted the good practice of Sellafield Limited’s effective application of Tier 2 (process owner assurance) to judge the adequacy of MSSS category 1 operating instructions ahead of the inspection.
For LC26, I identified no shortfalls requiring regulatory attention. I noted a minor observation that MSSS should consider the use of a pre-job briefing board, where appropriate, to ensure key hazards, their control measures and other important information is highlighted, as this is already being implemented at other facilities on the Sellafield site and is considered to represent good practice. I noted the good practice of effective collaboration between the Sellafield Limited DAPs and Authorised SQEPs (ASQEPs), and the Contractors’ Supervisors.
On balance, I was of the opinion that the regulatory observations raised do not warrant raising any Regulatory Issues.
The NI&IO participant and the Safety Representative were content with the outcomes of this inspection. Our findings were shared with, acknowledged and accepted by 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, I judge that the licensee has adequately implemented its arrangements for compliance with Licence Condition 10 (Training), Licence Condition 12 (Duly authorised and other suitably qualified and experienced persons), Licence Condition 24 (Operating Instructions) and Licence Condition 26 (Control and supervision of operations) in MSSS. I consider that an inspection rating of Green (no formal action) is merited for each of the Licence Conditions (10, 12, 24 and 26) at MSSS.