This intervention was undertaken on 21 – 22 January 2015 at Sellafield Limited’s Sellafield nuclear licensed site in Cumbria.
The inspection examined compliance with Licence Condition (LC) 10 (Training) in the Fuel Handling Plant and LC 36 (Organisational Capability) in Calder Hall.
Inspection of Licence Condition Compliance at nuclear licensed sites is an important element of ONR’s activities. ONR’s Sellafield programme has defined a programme of system inspections and LC compliance inspections to be undertaken on the Sellafield Site that focuses on the aspects of Sellafield’s operations that are most important to safety. These inspections, identified in ONR’s PP4 inspection plan which covers Sellafield Limited’s Magnox Operating Unit, are part of that programme.
The Fuel Handling Plant was selected for this inspection because of the importance of training to proposals to receive fuel from Sellafield legacy facilities. Calder Hall was selected for an Organisational Capability inspection in light of an event at the plant last year in which at operating rule was breached.
Planned compliance inspections were undertaken against the following:
The LC 10 inspection included a programme of meetings and inspection of the facility to assess whether the licensee has put in place, and is implementing suitable arrangements with regard to training for those staff whose roles may affect safety. A particular focus of the inspection was to review the preparation and adequacy of the approach being taken to training of staff ahead of the receipt of legacy fuel.
The LC 36 inspection included a programme of meetings and inspection of the Calder Hall Facility to assess whether the licensee has put in place, and is implementing arrangements to effectively manage organisational changes. A particular focus of this inspection was work being done to improve the safety culture within the facility, and the approach being taken to changes in the number of operating rules following the Loss of Dry Air Event in 2014.
N/A. A system inspection was not undertaken
The Licensee has put in place new arrangements for training and is in the process of making the transition to the site’s Systematic Approach to Training (SAT). My inspection indicated that both the legacy and SAT training material examined were of an adequate standard and that an appropriate approach is being taken to training of staff ahead of the receipt of legacy fuel. This training has built on and applied learning from experience gained in relation to the receipt and processing of Dounreay fuel and demonstrates active pursuit of potential improvements.
Whilst noting that both the legacy and SAT-derived training material examined were adequate, it was clear from my inspection that the more recent SAT material is of a higher standard, in particular with better underpinning analysis and linkage to the safety case. This reaffirms the importance of a timely transition to implementation of SAT within the facility. In relation to this, I reviewed the Operations Division Implementation Plan for SAT (which includes the Fuel Handling Plant) and whilst I consider the approach being taken to be duly risk-informed, I am concerned regarding the timescales and ultimate coverage of the implementation. This is a corporate rather than a facility-specific issue and I so will raise this with the ONR Corporate Inspector.
Taking all these factors into account, including the adequate standard of the training material examined, I assigned an IIS Rating of 3 (adequate) against LC 10.
My inspection indicated that following the Dry Air Event in 2014 the licensee is implementing a programme of work that includes appropriate initiatives to improve the human performance and safety culture within the facility and to update the safety case and associated operating rules. I found the human performance and safety culture aspects of this to be a targeted and considered programme of work informed by and consistent with the wider approach being taken on site, and supportive of the organisational capability and a healthy safety culture within the facility. I also found that the organisational baseline is being actively managed, with no vacancies which relate to nuclear safety.
Whilst recognising these positives and that the fundamental requirements of LC 36 are being met, I noted some specific procedural weaknesses relating to aspects of Calder Hall’s implementation of Sellafield Limited’s Management of Change (MoC) arrangements. These included a failure to document a MoC post implementation review, and a lack of suitably qualified and experienced resource across the facility to support a rigorous application of the MoC process.
Taking all these factors into account I assigned an IIS Rating of 4 (below standard) against LC 36. I have raised an Action on the facility and will record this on ONR’s Regulatory Issues database, which will be tracked to completion via routine regulatory interaction and through liaison with Sellafield’s internal regulator.
I judge the Fuel Handling Plant to be compliant with arrangements made under LC 10, justifying an IIS rating of 3 – Adequate.
From the evidence presented during the Calder Hall inspection, I have assigned an IIS rating of 4 (below standard) against LC 36 and will raise a Regulatory Issue to track Sellafield Limited’s resolution of my concerns.
There are no findings from this inspection that significantly undermine nuclear safety.