The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Sellafield site licensee (Sellafield Limited, SL) against a strategy defined by the ONR Sellafield Programme. In accordance with that strategy, Licence Condition (LC) compliance inspections in the Effluents and Encapsulation Operating Unit (E&EP OU) were carried out, as planned, in June 2016.
The purpose of this planned inspection was for the ONR to determine the adequacy of implementation of the licensee's formal arrangements for compliance with LC 10 (training) and LC 12 (duly authorised and other suitably qualified and experienced persons). No further pre-inspection targeting of discrete facility/plant was undertaken, as recent events within both Effluents and Encapsulation plants (and a related improvement plan) indicated that the compliance inspection should consider evidence of adequacy of compliance across the OU.
LC 10 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.
LC 12 requires the licensee to make and implement adequate arrangements to ensure that only suitably qualified and experienced persons perform any duties which may affect the safety of operations on the site.
On 23 June 2016, I carried out a one-day, on-site LC 10 and LC 12 compliance inspections within the E&EP OU. The inspection comprised discussions with SL staff, and reviews of plant records and other documentation. As part of my preparation for the delivery of this intervention, the following formal ONR guidance documentation was used:
This was not a system based inspection, and therefore no judgement has been made of the adequacy of implementation of any part of the safety case.
During my inspection, I sampled the delivery of all training required within both the Effluents and Encapsulation facilities, and reviewed the control of both the qualification scope and management of the staff training demand, in order to determine if the licensee had implemented their arrangements for compliance adequately.
I sampled the delivery of the qualification of formally appointed persons within the Effluents facilities, focusing on the effectiveness of initial and review assessments of the competence of plant Duly Authorised Person (DAP). In my opinion, the licensee has implemented their arrangements for compliance adequately.
Additionally, as part of my sample of plant personnel training and management of Suitably Qualified and Experienced Persons (SQEP) within the E&EP OU, I reviewed progress against an improvement plan that the licensee had initiated six months ago to address specific shortfalls in training, qualification, and relevant experience of some plant personnel that had been identified following a number of plant events in 2015. I consider that this improvement plan is on track, and that, if completed to time and scope, will strengthen the licensee's performance in the areas of adequate plant knowledge for key management roles, and effective delivery of safety-related change to plant.
From those areas sampled, I did not identify any significant shortfalls in the licensee's formal arrangements for compliance which would prompt an inspection of those arrangements earlier than currently planned.
I consider that the licensee has complied with all legal duties, and that there are only limited opportunities for further ALARP improvements. Therefore, it is my opinion that, against compliance with Licence Conditions 10 and 12, an IIS rating of Green (No Formal Action) is merited.
From the evidence sampled during these inspections, I judge that there was sufficient evidence that the licensee's formal arrangements for compliance with Licence Conditions 10 and 12 are being implemented adequately.