Executive summary
- Date(s) of inspection: December 2024
Aim of inspection
PTC has commenced its Enhanced Project Period (EPP), during which extensive modifications will be made to the facility. This work necessitates the use of staff and contractors. Recent operational experience identified deficiencies in the response to undercover alarms by contractors working on the facility. The aim of the inspection is to judge whether:
- AWE is adequately identifying the training that contractors require to work safely on the facility;
- AWE is providing the required to training to contractors; and
- AWE can demonstrate that contractors are competent, prior to accessing and undertaking safety important activities on the facility.
Subject(s) of inspection
- LC10 - Training - Rating: Amber
- LC12 - Duly authorised and other suitably qualified and experienced persons - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
An LC 10 (training) and LC12 (duly authorised and other suitably qualified and experienced persons) compliance inspection was undertaken in PTC on 12th December 2024. The provisional rating for the LC10 was given as AMBER with a reg issue to follow due to AWE's lack of demonstration of a systematic training needs analysis (despite this being an expectation in AWE’s own arrangements). ONR anticipates AWE will derive a pragmatic, forward looking response to the reg issue that will avoid requiring nugatory or retrospective work.
The provisional rating for the LC12 element was GREEN. However also ONR gained useful information in this area regarding potential topics of concern that will be sampled further during the approaching LC26 inspection (either in Feb or May).
Conclusion
For LC10, ONR sampled the facility induction training owned by PTC, titled ‘PTC Full Access Orientation’. This is a one day course provided and managed by PTC.
AWE presented the training material, assessment criteria and explained the way the training is conducted. From this, I gained confidence that important elements are included in the training (e.g. the necessary response to alarms), and in the training methods applied (e.g. presentation in the morning, followed by exercises in the afternoon to reinforce important aspects). I also gained confidence in the assessment methods and the treatment of individuals who do not meet the required standard. However, the PTC training manager was unable to provide a training needs analysis for this training and citied that the derivation of training needs was legacy and pre-dated the current AWE arrangements. I considered the absence of a training needs analysis to be a significant omission.
PTC explained it is developing new training (to support the people workstream of Enhanced Project Period (EPP)) which uses simulated activities to enable learners to gain competence without being in an active area or working with radioactive material. I recognised this as a positive initiative. However, again PTC was unable to provide a training needs analysis for this, or for any other training given on the facility. I reflected the regulatory position about the importance of a training needs to identify the competency requirements. I stated my judgement that the absence of this was a significant shortfall from good practice. It is also out with AWE’s LC 10 arrangements. As such I rated this aspect of the inspection as AMBER. I explained that a Regulatory Issue for PTC will be raised requiring AWE to demonstrate how adequate analysis is being undertaken to inform the design and development of future facility training.
For LC12, with respect to employees, AWE provided a clear demonstration as to how the competence of individuals who undertake work impacting safety is managed. During the inspection I tested AWEs processes for managing competence from the initial appointment of a new employee, including how the necessary competencies are assigned to the individual and how they are trained and confirmed competent through assessment. I also tested how a Line or Task Manager accesses and uses this data to make decisions about the competence of their team and how refresher training is prompted and booked. AWE provided adequate demonstration of their arrangements using their Safe Ops 365 competency management system and the underlying assessment records. One area was identified for further inspection associated with the veracity of the underlying job role data, which is managed by ‘people capability’. I considered it appropriate for AWE’s Internal Oversight team undertake this additional inspection activity.
With respect to contractors, I sampled delivery partner workers, as this is the primary route that will be used for the EPP. AWE provided a demonstration of how the competence of contractors is managed. This is split into three areas: (1) access to the facility; (2) discipline or craft competence; (3) task competence.
AWE directly manage the access of contractors to the facility. To gain unescorted access, contractors are required to have completed six training courses (e.g. covering criticality safety and facility awareness). Contractors are also expected to have familiarity with the facility through five supervised visits. I sampled records for this and found the evidence to be adequate. There was one exception where the arrangements indicate that a total of 10 hours of supervised familiarisation visits is required before unescorted access is granted. However, the inspected forms showed durations were far less than this. AWE suggested that this is due to poor wording in the arrangements. I provided advice for PTC to clarify the expectations and ensure they are clearly recorded in the arrangements and being complied with. AWE explained that access control is controlled via the card access system, and that unless approved as competent, the individual would be locked out of the facility. AWE explained that refresher training is required on an annual basis and that this tests knowledge of the facility alarms and their responses.
As part of their contract, the delivery partner manages the competence of the individuals they supply. AWE provide an oversight role and demonstrated how this is managed. AWE presented a training matrix, which identifies the competencies necessary to work on the facility (e.g. that of an electrician), the which individuals hold these competencies (including the expiry dates). In addition, AWE presented a self-assessment form for a supervisor who has worked on the contract, which details the individual competencies held by the individual. There was consistency in the information between the self-assessment form and the training matrix. I raised concern when I noted this individual's Construction Skills Certification Scheme (CSCS) card had expired. Whilst AWE confirmed that this individual was not currently working on the facility, AWE did not provide adequate evidence to demonstrate that they would not be able to work, instead indicating that some flexibility can be given, while individuals await a new card. I strongly questioned this and detailed my expectation that individuals with expired cards cannot continue working on the facility. The PTC AWE representative shared our expectation and committed to ensuring that this was not and would not happen.
In terms of task competence, AWE explained that prior to commencing any construction task, an individual would receive an induction, during which the individual would need to show their relevant in date qualifications. AWE presented an induction pack and the attendance record, which included names and the expiry of their qualifications. I explored if an individual could commence on a task without receiving the induction and I considered that AWE did not fully demonstrate this aspect. I provided advice for AWE to review their arrangements to ensure this process is robust. I considered this especially important given that during the approaching EPP up to 50 contractors will be working on the facility at once.
AWE explained that further task briefing is provided via pre job briefs using method statements and risk assessments. I intend to inspect this aspect as part of the forthcoming LC 26 inspection for the EPP.
AWE provided additional evidence in overseeing the competence of contractors through the use of its own risk-based inspections. AWE provided evidence of these for both the adequacy of the delivery partners arrangements for ensuring competence and also the implementation of them through task based inspections where the competence of individuals is confirmed. I considered these elements adequate.