Office for Nuclear Regulation

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Compliance inspection of Licence Conditions 26 (control and supervision of operations)

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 Sub Division. In accordance with that strategy, we carried out a Licence Condition (LC) compliance inspection on the B6 Diffuser Demolition Project operations, as planned. 

The purpose of this inspection was for the ONR to determine the adequacy of implementation of the licensee’s arrangements for compliance with LC 26 (control and supervision of operations). As planned, this was an unannounced inspection, which assisted in achieving the aims of the inspection.

The intervention was focussed implementation of site and project arrangements on plant and delivery of the command and control objectives described in the project documentation considered.

Interventions Carried Out by ONR

LC 26 requires that “the licensee shall ensure that no operations 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.”

On 13 August 2019, we carried out a planned one-day, unannounced, on-site LC 26 compliance inspection.  The inspection comprised discussions with SL staff, contractor staff and reviews of plant records and other documentation.  In carrying out this inspection, the following ONR guidance was used:

Explanation of Judgement if Safety System Not Judged to be Adequate

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.

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

The work planning delivery processes followed a defined daily routine of meetings, which we observed, and information was cascaded between meetings observed in a satisfactory manner. In addition, we observed the setting to work and delivery of a key operation during the inspection and sampled the hold point release process by supervisors and coordinators, as appropriate.

We judged that there was a good understanding by personnel of the concepts of control and supervision by both SL and contractor personnel sampled during the inspection. We consider that the project has satisfactorily implemented arrangements that define posts for the control and supervision of operations, the coordination of work and the interfaces between the contractors involved in the project and could demonstrate that all relevant stakeholders were controlling key steps of the tasks. These arrangements include the key roles in the event of identified emergency scenarios.

We did not find any safety shortfalls in the implementation of the arrangements of work control and no regulatory issues were raised.

From the evidence sampled, we consider that the licensee is compliant with its legal duties under LC26.  Therefore, we have rated the inspection as Green (no formal action) against Licence Condition 26.

From those areas sampled, we did not identify any safety shortfalls in the licensee’s formal arrangements for compliance, which would prompt a further inspection of those arrangements earlier than currently planned.

Conclusion of Intervention

From the evidence sampled during this inspection, we judge that there was sufficient evidence that the licensee’s formal arrangements for compliance with Licence Condition 26 are being implemented adequately. There were no regulatory findings of significance and no follow-up regulatory action is required.