Office for Nuclear Regulation

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Planned compliance inspections of LC12 and LC26

Executive summary

The Office for Nuclear Regulation (ONR) undertakes all regulatory interactions with the Sellafield site licensee (Sellafield Limited, (SL)) against a strategy defined by the ONR Sellafield Sub Division. This planned intervention was undertaken as part of the ONR 2019/20 Intervention Plan.

Purpose of Intervention

These planned core licence condition (LC) inspections were carried out to determine the adequacy of SL’s implementation of its corporate arrangements for compliance with LC12 – Duly authorised and other suitably qualified and experienced persons and LC26 Control and supervision of operations, at the Oxide Fuel Storage Group (OFSG) at Sellafield.

Interventions Carried Out by ONR

I carried out a one day LC compliance inspection against LC12, Duly authorised and other suitably qualified and experienced persons and a half day inspection against LC26, Control and supervision of operations . The LC12 inspection comprised a review of LC12 related documentation and records, and discussions with personnel responsible for implementing the LC12 corporate arrangements. The LC26 inspection comprised a visit to the B310 facility, observation of the Plant Operations Control Centre (POCC) Meeting, a review of the Duly Authorised Person’s (DAP) Log, observation of an operation (including an inspection of the associated procedures) and a check of the qualifications of those persons conducting the operation.

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

For LC12 I sampled the records of two DAPs, one Appointed Suitably Qualified and Experienced Person (ASQEP) (appointed in accordance with LC28(6)(d)) and one crane driver. I am satisfied that the individuals sampled are qualified and where relevant appointed in accordance with Sellafield’s corporate arrangements for LC12. However, I identified a shortfall within the corporate arrangements in relation to the assessment standard to be used for the requalification of DAPs. I spoke with the LC12 Process Owner who confirmed that OFSG is compliant with the current arrangements, but noted that a recent Tier 2 audit had identified similar issues and this was in the process of being addressed. I will raise my concern to the ONR Sellafield Corporate Inspector for consideration. I identified a minor problem with the records for a number of the DAPs in relation to the signatures on the assessment records and provided regulatory advice which was accepted by the Head of Operations. I also identified a minor shortfall where a sampled training guide did not reflect updated training requirements; I have raised a Level 4 Regulatory Issue to capture this shortfall.

For LC26 I found that operations were adequately controlled and supervised by the DAP. The POCC Meeting was attended by key personnel and was effective. The operation I witnessed was undertaken by suitably qualified and experienced persons, with written instructions being used and records complete.

Conclusion of Intervention

On the basis of the evidence gathered during the inspection, and notwithstanding minor shortfalls in relation to the signatures on the assessment records and a requirement to review the training courses within the training guides, I judge that OFSG has adequately implemented the arrangements for LC12 and LC26 and merit an assessment rating of Green. I have identified a potential issue in relation to the adequacy of the DAP process in relation to the assessment standard to be used for re-qualification panels and I will pass on this concern to the ONR Sellafield Corporate Inspectors for consideration.