This intervention was undertaken on 24 and 25 November 2015 at Sellafield Limited’s (SL) Sellafield nuclear licensed site in Cumbria, and focussed on the Magnox Reprocessing Medium Active Evaporation and Thermal Denitration Plant (MAETDP). The MAETDP was selected for this intervention because there are significant on and off-site consequences arising from certain fault scenarios identified in the plant safety case.
Inspection of Licence Condition (LC) compliance at nuclear licensed sites forms a significant part of ONR’s activities. ONR’s Sellafield Programme has defined a programme of safety system inspections and LC compliance inspections to be undertaken on the Sellafield site and this is a key aspect of ONR’s regulatory strategy for the Sellafield site. Undertaking this planned intervention is consistent with this strategy, and is identified on ONR’s PP4 inspection plan which covers SL’s Magnox Reprocessing activities.
LC26 ‘Control and Supervision of Operations’ requires the licensee to ensure that 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 by the licensee.
I completed the LC26 compliance inspection in accordance with the following ONR guidance:
I was supported on this inspection by a Human Factors specialist inspector. We undertook the inspection over two days, comprising a number of discussion sessions and plant walk downs. We focussed on three areas:
N/A. This was not a safety system inspection.
For plant operations, based on our samples, we confirmed those responsible for control and supervision of operations are Duly Authorised Persons (DAPs) who are appropriately trained, have clear roles and responsibilities, and sufficient time to effectively discharge their duties. From our findings, we were satisfied with control and supervision of plant operations within MAETDP. We shared our observations with SL, who noted our points.
For maintenance activities, based on our samples, we confirmed those responsible for control and supervision of operations are DAPs who have clear roles and responsibilities, and sufficient time to effectively discharge their duties. We noted that the maintenance DAPs are not appropriately trained in control and supervision duties; however, based on a task observation, we were satisfied with the delivery of control and supervision of maintenance activities within MAETDP. We shared the discrepancies we noted with the Integrated Work Management work pack with SL, who noted the points.
We confirmed those responsible for control and supervision of contractors are not DAPs and, in our opinion, are not appropriately trained. Whilst practices noted at Magnox Reprocessing are in compliance with SL’s corporate arrangements for control and supervision of contractors, we judged there to be some ambiguity about roles and responsibilities. Furthermore, we did not consider that Superintending Officers (SOs) and Nominated Representatives (NRs) had sufficient time to effectively discharge their duties. We shared our observations with SL, who noted and accepted our concerns. Recognising the local issue, we asked SL to strengthen the arrangements for control and supervision of contractors within Magnox Reprocessing. I have raised a Regulatory Issue to capture this point, and will manage it to closure as part of my routine regulatory engagement with SL. Our finding that the site-wide arrangements regarding control of contractors should be improved had previously been identified and is the subject of a Regulatory Issue that is being progressed by the Programme’s Corporate Inspector.
On balance, I judge an IIS rating of 4 (below standard) to be appropriate against LC26. Whilst SL’s arrangements for control and supervision of plant operations meet ONR’s guidance requirements, there are some specific weaknesses around control and supervision of maintenance activities and contractors. In making this judgement, I took account of the ongoing ONR intervention on control and supervision, and that SL is strengthening the corporate arrangements for control and supervision. We also took account of Magnox Reprocessing proactively enhancing the arrangements for control and supervision of contractors in advance of the inspection, and SL’s acceptance of the requirement to further strengthen these arrangements.
Based on the evidence gathered, no significant matters have been identified that are likely to impact on nuclear safety on the Sellafield site at this time.