Executive summary
Date(s) of inspection: August 2024
Aim of inspection
The aim of this inspection is to determine whether Nuclear Restoration Services are planning and implementing modifications appropriately targeting the Wet Intermediate Level Waste Retrieval & Encapsulation Plant (WILWREP). It will also aim to determine whether operators are suitably trained and there will be adequate control and supervision on this plant which is due to commence commissioning.
Subject(s) of inspection
- LC10 - Training - Rating: Green
- LC22 - Modification or experiment on existing plant - Rating: Green
- LC26 - Control and supervision of operations - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
I led a planned compliance inspection on LC10 (Training), LC22 (Modification or Experiment on existing plant) and LC26 (Control and Supervision of Operations). The inspection team comprised the nominated site inspector and a Human Factor Specialist inspector.
For LC22, the licensee provided evidence that they have a mature and appropriate modification arrangements that have suitable governance. However, I identified that the licensee could improve the modification closure process to meet recommended good practice. Nevertheless, it is my opinion that NRS were able to demonstrate compliance with LC22 arrangements and I award a rating of Green.
For LC10, the licensee provided evidence that appropriate and suitable training will be provided to operators prior to the commencement of WILWREP. However, I identified that the process followed to determine the competence and training requirements for WILWREP was not in line with the Systematic Approach to Training (SAT), considered as Relevant Good Practice (RGP) and the process did not involve a training SQEP. During the inspection, it was not possible to determine whether the competence and training process within NRS is based on a SAT approach and therefore it is proposed that a further engagement with the central team may be appropriate. Based on the Human Factors Inspectors opinion, I consider a Green rating to be appropriate for LC10.
For LC26, the licensee provided evidence that they have suitable arrangements for control and supervision at WILWREP. However, for the future projects at the site the same approach may not be successful due to the tasks undertaken by the Team Leader. Nevertheless, it is the Human Factors Inspectors opinion that NRS were able to demonstrate compliance with LC26 arrangements and I award a rating of Green.
During the inspection the licensee provided evidence to close out RI-12110 which was confirmed by the safety representatives. The regulatory issue is now closed.
I also held a regulatory walk round with the site safety representatives.
Conclusion
I consider that the licensee is adequately implementing the requirements of LC 22, based upon my sampling and the evidence presented by the licensee. I therefore judge that, an ONR inspection rating of adequate (GREEN) is appropriate for this intervention.
For LC10 , the process followed to determine the competence and training requirements for WILWREP was not in line with the Systematic Approach to Training (SAT) considered as Relevant Good Practice (RGP) and the process did not involve a training SQEP. However, given the relatively small modification, and the fact that the majority of the tasks remain the same as for previous operations, I consider the training to be appropriate and proportionate. I note that the important additional competence requirements, e.g. those relating to COSHH, have been recognised and addressed. Further confidence is taken from the familiarisation activities that have already been completed and that will be completed during commissioning.
During the inspection, it was not possible to determine whether the competence and training process within NRS is based on a SAT approach and therefore it is proposed that a further engagement with the central team may be appropriate. ONR advised that they would discuss this further within ONR before identifying what action to take. Based on my findings, I consider a Green rating to be appropriate for LC10.
For LC26, confidence was gained during the inspection that the DAP would have control over activities on the facility and that adequate supervision was in place to ensure safe operations. Based on my findings, I consider a Green rating to be appropriate.