Office for Nuclear Regulation

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Licence Condition 10 & 12 inspection of training and capability in Decommissioning Division

Executive summary

Purpose of intervention

This intervention was undertaken on 2 December 2014 at the Sellafield Limited (SL) nuclear licensed site in Cumbria.

Inspection of Licence Condition (LC) compliance at nuclear licensed sites is an important aspect of ONR’s activities. ONR has defined a programme of system inspections and LC compliance inspections, which focus on the aspects of Sellafield Limited’s operations that are most important to safety and legal compliance. This inspection is identified on ONR’s PP3 inspection plan which covers Sellafield Limited’s Decommissioning Division.

I carried out an inspection of the Licensee’s implementation of its arrangements for Licence Conditions 10 (LC10, Training) and 12 (LC12, Duly Authorised and other Suitably Qualified and Experienced Persons) in the Decommissioning Division.  These LCs were selected for inspection in view of the importance of staff training and experience and the appointment of Duly Authorised Persons (DAPs) to nuclear safety in Decommissioning Division.

Interventions Carried Out by ONR

LC10 requires the licensee to make and implement adequate arrangements for suitable training for those on site who have responsibility for any operations which may affect safety.  LC12 requires the licensee 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 required by the Licence Conditions. This LC also allows for the appointment of Duly Authorised Persons to control and supervise operations which may affect plant safety.

The inspection focused competency assurance arrangements for Decommissioning Division. This was carried out against the requirements of LC10 and LC12 and ONR’s guidance for LC10 & 12 as defined in NS-TAS-GD-027 ‘Training and Assuring Personnel Competence’.

The inspection was carried out through office-based examination of procedures and records and interviews with staff. The intervention was undertaken by the Site Inspector supported by an ONR Human Factors Specialist Inspector.

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A – This was not a Systems Based Inspection.

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

I inspected the implementation of SL’s LC10 and LC12 arrangements. SL is currently in the process of implementing the Systematic Approach to Training (SAT) process. This includes reviewing all existing roles and associated training material.

SL was able to demonstrate a good level of planning; a risk-based process has been developed and applied which has resulted in a prioritised programme for the implementation of SAT and reduced timescales for its roll out.  The training organisation, whilst currently under its target headcount numbers, is well populated, structured and defined. In addition, SL was able to provide evidence of robust governance arrangements, at both Directorate and facility levels. Good use of metrics was demonstrated to show monitoring of training and capability processes. Prior to this inspection ONR had already recognised that the focus on training delivery has improved and the reporting of each overdue/missed training event as a learning opportunity was considered good practice. These provide confidence that SL has the enablers in place to deliver competency assurance aligned with Best Practice in the Decommissioning Division.

It was encouraging to receive feedback from a safety representative that the staff perception is that training has improved within Decommissioning Division.

I reviewed a sample of the DAP training and appointment process. This highlighted a number of inconsistencies in the application of SL’s process. These related to:

The level and format of evidence provided in support of DAP appointments. Notably, the interview panel questions and responses, completion of mentor guides and associated sign off by Subject Matter Experts (SMEs).

Alignment between SL’s guidance document on control and supervision and the DAP evaluation through the associated training module. I also noted the emphasis appeared to be on describing control rather than methods and application of supervision.

These inconsistencies were particularly apparent in the material developed by a contractor. Nevertheless, there was good alignment between what is being produced and the expectations of SAT. I do not consider these inconsistencies to represent significant deficiencies, but rather potential for process ‘creep’, which if not controlled may result in shortfalls against best practice.

I reviewed the training, competence and appointment records for DAPs and key safety related roles in the Legacy Ponds and Silos (LP&S). The review highlighted that a number of different formats had been used for the DAP assessment material on recent projects. Whilst all of these broadly met the SAT model, I challenged the rationale and acceptability for the number of differing formats in the short period demonstrated. SL agreed to review the status of compliance for the differing formats and consider how these could be improved in future to incorporate the best elements of each example presented.

The training records for key plant operators on LP&S were reviewed on the Computerised Training Management System (CTMS), and this demonstrated that all mandatory training had been completed for the samples inspected, and that adequate evidence was available to demonstrate that personnel were within the refresher periods for all mandatory training.

Conclusion of Intervention

Overall I judged the licensee’s compliance with LC10 and LC12 to be adequate. Although there were areas of best practice demonstrated, some inconsistencies were identified in the implementation of SAT. I consider that once the implementation of the SAT programme is more mature and consistency in its implementation is improved, this could be classed as meeting best practice, and so deserve a higher IIS rating.

A number of minor actions and recommendations were agreed with the licensee, and these will be followed up by ONR as part of normal regulatory interactions with the licensee.