In accordance with the Office for Nuclear Regulation’s (ONR’s) Sellafield Strategy, each year ONR performs a series of planned compliance inspections of core licence conditions, targeting those facilities with the potential to give rise to off-site effects to the public.
This planned, core licence condition inspection was carried out to assess Sellafield Ltd.’s (SL’s) compliance with licence conditions (LC) 12 – Duly Authorised and other Suitably Qualified and Experienced Persons and 26 – Control and Supervision of Operations, at the Thermal Oxide Reprocessing Plant (THORP) at Sellafield.
LC 12 requires SL 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 or any other duties assigned by or under these conditions or any arrangements required by these conditions…. The aforesaid arrangements shall also provide for the appointment, in appropriate cases, of duly authorised persons to control and supervise operations which may affect plant safety”
LC 26 requires SL to ensure that “…no operations which may affect safety 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 carried out a combined licence compliance inspection against licence conditions 12 and 26 comprising discussions with SL personnel and reviews of SL records and processes. I utilised the following ONR inspection guidance:
In addition I carried out a number of fact-finding interventions relating to event follow-up and looked at THORP’s progress with the development and implementation of its cultural and behavioural improvement plan.
N/A as this was not a safety systems inspection.
When fully implemented, I consider that revisions being made to the Shift Team Coordinators’ role to clarify and reinforce leadership aspects, and to enhance control and supervision to better support the plant’s Duly Authorised Persons should result in improvements in the effectiveness of control and supervision of day-to-day operations within THORP.
The control and supervision rationalisation project being undertaken in response to changes in SL’s corporate arrangements for LC26, appears both structured and systematic. This should result in an underpinned control and supervision baseline with increased clarity of role responsibilities/accountabilities for those appointed to control or supervision roles under either LC12 or 26. THORP will however need to ensure that these revised responsibilities provide adequate clarity in regard to responsibilities for compliance with LC28 – Examination, inspection, maintenance and testing.
Although some minor areas for improvement were identified with respect to the appointment process for Duly Authorised Persons, overall THORP has appropriately implemented what appears to be a robust competency framework to support the appointment process.
Discussions with plant personnel indicate initiatives being undertaken by the plant to improve understanding of best practice control and supervision techniques and approaches are proving effective.
THORP is making adequate progress with the development of a suitable behavioural and cultural improvement plan and subject to incorporating a number of identified areas suggested by ONR, I am confident that the final plan will meet regulatory expectations.
On the basis of the evidence gathered during this inspection, I judge that inspection ratings of GREEN (No formal action) are appropriate for compliance against both LC 12 – Duly authorised and other suitably qualified and experienced persons and LC 26 – Control and supervision of operations. This is because I found SL to be compliant with its legal duties with only minor areas for further improvement being identified.
Minor areas for improvement will be taken forward as part of routine regulatory business.