Office for Nuclear Regulation

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Compliance inspection of Licence Condition 12 (Duly Authorised and other Suitably Qualified and Experienced Persons)

Executive summary

Purpose of Intervention

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 if the PF&S OU is adequately implementing SL’s site wide arrangements for compliance with Licence Condition 12 (Duly Authorised and other Suitably Qualified and Experienced Persons -DAP & SQEP). The intervention targeted the implementation of Sellafield’s arrangements within the Sellafield MOX Plant (SMP) of its Plutonium Management Facilities (South) (PMF(S)) organisation. This LC and facility were selected for inspection in view of the importance of good standards of control, supervision and competence in operations involving plutonium and also as a follow up to review LC12 improvement work completed by PMF(S) since the fuel handling events in mid to late 2016

The overall adequacies of SL’s site-wide LC 12 arrangements are considered separately in other ONR inspections.

Interventions Carried Out by ONR

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”

I carried out a licence compliance inspection against LC 12 comprising discussions with SL personnel and reviews of SL records and processes.  I utilised the following ONR inspection guidance:

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A as this was not a safety systems inspection.

Key Findings, Inspector's Opinions and Reasons for Judgements Made

During my inspection I sampled evidence associated with the licensee’s compliance with its formal arrangements for LC12 within SMP and examined a sample of SL’s Role Specifications for DAP posts, arrangements for authorisation of staff into DAP posts, training records and the recent event logs to determine if the licensee had implemented its arrangements for compliance adequately.

The licensee demonstrated a good understanding of the requirements of LC 12 and provided robust evidence to demonstrate that understanding for the SMP facility.     

I consider that the licensee has complied with all legal duties; therefore, it is my opinion that against compliance with Licence Condition 12, an inspection rating of Green (No Formal Action) is merited.

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. 

Conclusion of Intervention

From the evidence sampled during this inspection, I judge that there was sufficient evidence that the licensee’s formal arrangements for compliance with Licence Condition 12 are being implemented adequately.

My findings were shared with and accepted by the licensee as part of normal inspection feedback.  I have not raised any Regulatory Issues as a result of this inspection.