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, Decommissioning, Fuel and Waste Programme. The inspection plan PP1 for the Plutonium Finishing and Storage Facilities Operating Unit (PF&S OU) details a strategic programme of regulatory Licence Condition (LC) compliance inspections.
This planned licence condition inspection was carried out to assess SL’s implementation of its site wide arrangements for compliance with Licence Conditions (LC) 12 – Duly Authorised and other Suitably Qualified and Experienced Persons and 26 – Control and Supervision of Operations, in Finishing Line 6 (FL6) of its Plutonium Management Facilities (South) (PMF(S)) organisation. The adequacy of SL’s overarching, site-wide arrangements is assessed in other ONR inspections. These LCs and this facility were selected for inspection in view of the importance of good standards of control, supervision and competence in operations involving plutonium.
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 LCs 12 and 26 comprising discussions with SL personnel and reviews of SL records and processes. I utilised the following ONR inspection guidance:
N/A as this was not a safety systems inspection.
During my inspection, I sampled the delivery of training required within PMF(S) FL6, and reviewed the control of both the qualification scope and management of the staff training, in order to determine if the licensee had implemented its arrangements for compliance adequately.
I sampled the delivery of the qualification of formally appointed persons within FL6, focusing on the effectiveness of initial and review assessments of the competence of the plant’s Duly Authorised Persons (DAP). I noted there is a robust process for assessing and appointing the DAPs that makes good use of mentoring through their training by Subject Matter Experts (SMEs) from different disciplines within FL6. In my opinion, the licensee has implemented its arrangements for compliance adequately.
Printouts from the ODMS staff information management system of the training records for key plant operators on FL6 were reviewed, and this indicated that all mandatory training had been completed for the sample inspected, and that adequate evidence was available to demonstrate that personnel were within the refresher periods for all mandatory training.
The control and supervision rationalisation project currently being undertaken in response to changes in SL’s corporate arrangements for LC26 appears both organised and efficient. As part of this project PMF(S) has also reviewed its DAP nuclear baseline status and produced an updated baseline that will result in increased clarity of role responsibilities and accountability for those appointed to control or supervision roles under either LC12 or 26.
From those areas sampled, I did not identify any significant shortfalls in the licensee’s site-wide arrangements for compliance which would prompt an inspection of those arrangements earlier than currently planned.
I consider that the licensee has complied with its legal duties in the areas I sampled, and that there are only limited opportunities for further ALARP improvements. Therefore, I have awarded a rating of Green (No Formal Action) against SL’s compliance with Licence Conditions 12 and 26.
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 12 and 26 are being implemented adequately at FL6.