The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Sellafield site licensee (Sellafield Ltd, SL) against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. In accordance with this strategy, a Licence Condition (LC) 10 (Training) and 12 (Duly authorised and other suitably qualified and experienced persons) arrangements inspection was carried out, as planned, on 30 November - 1 December 2017. The purpose of the inspection was to determine whether SL's arrangements are adequate to ensure the site's compliance with LC10 and 12. The inspection drew on intelligence from other ONR inspections which examine the implementation of the arrangements in operating facilities.
A team comprising the ONR Corporate Inspector, Human Factors Lead Inspector and Project Inspector carried out the inspection. The inspection focussed on the adequacy of SL's arrangements for compliance with LC10 and 12 and intelligence from events, inspections and assessments (by ONR and SL) relevant to these LCs.
The inspection comprised a review of relevant management system processes and records, a review of event trends and findings from inspections / assessments, and discussion with SL's Head of Profession (Training) and training practitioners from different parts of SL's business. ONR's technical assessment guide NS-TAST-GD-027 (Training and Assuring Personnel Competence) formed the basis for the inspection.
Not applicable as this was not a system based inspection.
I found SL's training function to be well led with clear ownership and accountability for the arrangements for compliance with LC10 and 12. There was evidence of good interaction and communication between training practitioners and a commitment to maintaining and improving the arrangements based on learning from their application.
I found SL's arrangements for compliance with LC10 and 12, which are based on a systematic approach to training (SAT), to be largely in line with relevant good practice, including ONR's expectations (NS-TAST-GD-027). I considered the role performed by Training Managers / Leads to be key in supporting implementation of the arrangements. There was also evidence of effective assurance by the Head of Profession (Training), leading for example to improvements in the ability of line management to verify competence prior to setting people to work.
I found minor shortfalls in two areas of SL's arrangements: (i) insufficient justification for the continued use of legacy training materials and (ii) insufficient justification for decisions not to carry out training, eg when new plant is introduced or existing plant modified. This does not align with ONR's expectation of a targeted and proportionate application of SAT. I have raised a regulatory issue for SL to correct these shortfalls.
I also made a number of other observations where I considered that SL could further improve its arrangements, including greater clarity in training for ‘off-normal' conditions, inclusion of quality aspects in training metrics, prioritisation of development of the technical competency framework for the training profession, greater clarity on SL's overall strategy for training and further expansion of the techniques used to evaluate training effectiveness.
ONR and SL had a shared understanding of the future challenges facing SL on training, including implementation of the technical competency framework across its organisation (to enhance assurance of competence of managers) and an expectation of greater efficiency in application of training processes (part of SL's re-alignment into value streams). Recognising these challenges, ONR will maintain dialogue with the Head of Profession (Training) on the improvements SL is pursuing.
I consider that the licensee's arrangements are adequate to ensure the site's compliance with LC10 and 12 with minor shortfalls only which I have addressed by raising a Level 4 regulatory issue. It is my opinion that that an inspection rating of ‘Green' (no formal action) is merited.