- Site: Sellafield
- IR number: 21-181
- Date: March 2022
- LC numbers: 12, 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, a planned Licence Condition (LC) compliance inspection was carried out at the Waste Vitrification Plant (WVP), part of the High Level Waste Plants (HLWP).
The purpose of this inspection was to confirm that Sellafield Limited is adequately implementing its arrangements for LC12 (Duly Authorised and other Suitably Qualified and Experienced Persons) and 26 (Control and Supervision of Operations) at HLWP.
Interventions Carried Out by ONR
This was a planned LC12 and 26 compliance inspection at HLWP. The inspection was undertaken on 9 and 10 March 2022 led by a Leadership and Management for Safety (LMfS) Specialist Inspector and a Chemistry Specialist Inspector and supported by the Site Inspector for HLWP. A representative of Sellafield Limited’s Nuclear Intelligence and Independent Oversight (NI&IO) function also participated. The inspection comprised of discussions with Sellafield Limited personnel, a review of plant documentation, a review of training records and a plant visit.
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.
LC26 requires Sellafield Limited to ensure no operations are carried out which may affect safety, except under the control and supervision of SQEPs appointed for that purpose.
As part of the preparation for the delivery of this intervention, the following ONR guidance was used:
- NS-INSP-GD-012 “Licence Condition 12 - Duly Authorised and Other Suitably Qualified and Experienced Persons”;
- 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 LC12, we identified no shortfalls requiring regulatory attention. We found evidence that SQEPs had been duly appointed. We observed effective collaboration between the Sellafield Limited off-going and oncoming DAPs and Appointed SQEPs (ASQEPs) during plant handovers, which were supported by appropriate records. We provided regulatory advice in relation to minor administrative errors associated with the DAP and ASQEP records. We judged that this 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 provided regulatory advice in relation to having the MSC minutes explicitly record confirmation that the quorum requirements are met for the papers being considered. In addition, we noted that HLWP may wish to consider reviewing its Conservative Decision Making (CDM) and Operational Decision Making (ODM) records to ensure actions were completed in a timely manner. We judged that these minor regulatory observations did not warrant raising any Regulatory Issues.
Conclusion of Intervention
Taking the above key findings into account, and noting the ONR guidance on inspection ratings, we judge that Sellafield Limited has adequately implemented its arrangements for compliance with LC12 (Duly Authorised and other Suitably Qualified and Experienced Persons) and LC 26 (Control and Supervision) in HLWP. We therefore consider that an inspection rating of Green (No Formal Action) for each of the licence conditions targeted is merited. No Regulatory Issues were raised.