- Site: Sellafield
- IR number: 21-176
- Date: February 2022
- 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 Ltd) against a strategy defined by the ONR Sellafield Subdivision. In accordance with this strategy, a planned Licence Condition (LC) compliance inspection was carried out at Thermal Oxide Reprocessing Plant (THORP).
The purpose of this inspection was to confirm that Sellafield Ltd is adequately implementing its 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 THORP. The intervention was part of a series of interventions under the theme of Disciplined Operations.
Interventions carried out by ONR
The inspection was a planned LC10, 12, 24 and 26 intervention conducted at THORP and was undertaken on 22 - 23 February 2022 by the ONR Site Inspector for THORP, a Leadership and Management for Safety (LMfS) Specialist Inspector, a Human Factors (HF) Specialist Inspector, a HF Nuclear Associate and a Chemistry Specialist Inspector. The inspection comprised discussions with Sellafield Ltd personnel, the observation of key meetings related to the control of operations, a review of a targeted sample of Sellafield Ltd’s documentation and a plant walkdown. A representative of Sellafield Ltd’s Nuclear Intelligence and Independent Oversight (NI&IO) function also participated.
LC10(1) requires the licensee 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(1) requires the licensee to make and implement adequate arrangements to ensure that only suitably qualified and experienced persons (SQEPs) 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. LC12(2) provides for the appointment, in appropriate cases, of duly authorised persons (DAPs) to control and supervise operations which may affect plant safety.
LC24(1) requires the licensee to ensure that all operations which may affect safety are carried out in accordance with written instructions. LC24(2) requires the licensee to ensure that such operating instructions include any operating instructions necessary to ensure that any operating rules are implemented.
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 by the licensee.
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 in 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 immediate regulatory attention. We noted that THORP is close to the site target of 95% complete annual SQEP periodic reviews, which demonstrated suitable progress in this site-wide improvement initiative. We welcomed THORP’s proactive approach to providing feedback to the central training team, to ensure that centrally provided training meets the needs of THORP personnel. We identified two minor shortfalls against Sellafield Limited’s LC10 arrangements. Training Programme Descriptions (TPD) were still to be updated for a significant proportion of THORP personnel, to align training needs with THORP’s transition into Post Operational Clean Out (POCO). Additionally, some aspects of the DAP emergency role refresher training had gone overdue for six members of the THORP DAP community. We have raised two level 4 (i.e. lowest level) regulatory issues to capture these shortfalls. Overall, we judged that relevant good practice was met with regards to LC10. Where shortfalls were identified, these represented minor failures to implement Sellafield Limited’s LC10 compliance arrangements, and suitable follow up actions were underway to ensure their timely resolution.
For LC12, we identified no shortfalls requiring regulatory attention. We found evidence that SQEPs had been duly appointed. We observed effective collaboration between the Sellafield Ltd off-going and incoming DAPs and Appointed SQEPs (ASQEP) during plant handovers, which were supported by appropriate records.
For LC24, we identified no shortfalls requiring regulatory attention. Overall, the quality of procedures sampled was judged to be adequate. However, we provided regulatory advice relating to minor shortfalls identified, in particular regarding reinforcing the standard for adherence to continuous use instructions, adherence to the red-penning process and the application of Sellafield Ltd’s LC24 standards to method statements (as described in its corporate arrangements). We judged that these minor regulatory observations did not warrant raising any Regulatory Issues.
For LC26, we identified no shortfalls requiring regulatory attention. We found that SQEP personnel had been appointed and were effectively controlling and supervising operations. We considered the POCO Plant Operations Control Centre (POCC) to be exemplar; it was excellently organised with good use of visual management boards.
We provided further regulatory advice regarding some minor areas for improvement and encouraged Sellafield Ltd to incorporate them into its Conduct of Operations Improvement Programme, as appropriate. Additionally, we encouraged Sellafield Ltd to consider the efficacy of its communication channels between the central maintenance organisation and THORP facility management team, to ensure responsibilities are clearly understood and that issues can be effectively and efficiently addressed.
Conclusion of intervention
Taking the above key findings into account, and noting the ONR guidance on inspection ratings, we judge that Sellafield Ltd has adequately implemented its arrangements for compliance with LC10 (Training), LC12 (Duly authorised and other suitably qualified and experienced persons), LC24 (Operating instructions) and LC 26 (Control and supervision of operations) at THORP. We therefore consider that an inspection rating of Green (No Formal Action) for each of the licence conditions targeted is merited. Two level four regulatory issues have been raised to ensure regulatory oversight of THORP’s planned activities, to secure the required improvements.