- Site: Sellafield
- IR number: 21-140
- Date: December 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 in Special Nuclear Materials North (SNM(N)), 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 SNM(N).
Interventions Carried Out by ONR
The inspection was a planned LC10, 12, 24 and 26 inspection at SNM(N) and was undertaken on the 7 and 8 December 2021 by the ONR Site Inspector for the SNM Value Stream, a Leadership and Management for Safety Specialist Inspector, a Human Factors Inspector, a Human Factors Nuclear Associate 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. From a sample we found evidence that operators had completed suitable training. We noted some minor observations and provided non-formal regulatory advice. We were of the opinion that these minor regulatory observations did not warrant raising any Regulatory Issues.
For LC12, we identified no shortfalls requiring regulatory attention. On plant we noted a good practice associated with the handover and pre-job briefs between Team Leaders. We found evidence that suitably qualified and experienced persons had been duly appointed.
For LC24, we identified no shortfalls requiring regulatory attention. On plant we saw evidence that operations are being conducted in line with written instructions. Based on the Operator Instructions sampled, we were of the opinion that these were adequate. We noted that there is an existing open Level 4 (i.e., lowest level) Regulatory Issue 8707 related to the use of continuous use instructions at SNM(N). We identified minor observations related to SNM(N) reviewing its operator aids to ensure they meet the Sellafield Limited requirements and redesignate where appropriate; enrolling SNM(N) instructions authors on the recently introduced corporate course on writing Operator Instructions ; and confirming whether the corporate procedure for operator rounds (SLP 1.05.13.01) is met. Given the existing Level 4 (i.e., lowest level) Regulatory Issue 8707, we were of the opinion that the regulatory observations noted do not warrant raising any new Regulatory Issues.
For LC26, we identified no shortfalls requiring regulatory attention. We found that suitably qualified and experienced personnel had been appointed and were effectively controlling and supervising operations. We judged there to be a minor shortfall against Sellafield Limited’s LC26 arrangements as SNM(N)could not provide evidence that a Control and Supervision Organisational Baseline had been produced in accordance with the requirements of the Control and Supervision Manual. Therefore, we have raised the following Level 4 (i.e., lowest level) Regulatory Issue (ref. 10494):
- SNM(N) to comply with Sellafield Limited’s corporate arrangements for producing and reviewing a Control and Supervision Baseline.
We noted minor observations associated with the Plant Operations Control Centre (POCC) meeting including consistent use of three-way communications, the phonetic alphabet and a roll call to ensure the POCC meeting was quorate. Related to SNM(N) Conduct of Operations Improvement Programme, we noted some minor observations associated with opening up training to a wider cohort of personnel to aid understanding of the Programme (including Leader in the Field); engagement with the Safety Representatives community; and establishing a mechanism to share applicable feedback of key themes arising from the Leader in the Field programme. Notwithstanding the above Level 4 (i.e., lowest level) Regulatory Issue (ref. 10494), we were of the opinion that the regulatory observations noted do not warrant raising any further Regulatory Issues.
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 SNM(N). 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. One level four (i.e., lowest level) regulatory issue (ref. 10494) has been raised in order to gain oversight of SNM(N) producing a Control and Supervision Baseline to comply with Sellafield Limited’s corporate arrangements.