Office for Nuclear Regulation

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To conduct LC12 and LC 26 compliance inspections at Sellafield Limited

Executive summary

Purpose of intervention

This intervention was undertaken on 28 – 30 January 2015 at Sellafield Limited’s (the licensee) Sellafield nuclear licensed site in Cumbria.

Inspection of Licence Condition (LC) compliance at nuclear licensed sites forms a significant part 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, this is a key aspect of ONR’s regulatory strategy (for the Sellafield site).  The inspections undertaken within this intervention are part of that programme and are identified on ONR’s PP4 inspection plan which covers Sellafield Limited’s Magnox Operating Unit.

Interventions Carried Out by ONR

LC12 ‘Duly Authorised and other Suitably Qualified Persons’  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. These arrangements shall also provide for the appointment in appropriate cases, of duly authorised persons to control and supervise operations which may affect plant safety. The objective of this inspection was to review the adequacy of the arrangements for LC12, focusing on Control Room operations, in order to provide assurance that Duly Authorised Persons (DAPs) are competent to undertake control and supervision of operations important to safety and to support appropriate operational decision making. In addition, the inspection reviewed the competency arrangements for plant appointed Subject Matter Experts.

LC26 ‘Control and Supervision’ requires the licensee to 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. 

I completed compliance inspections against these LCs in accordance with the following ONR guidance:

It should be noted, that the compliance inspections reported here formed part of a fact finding intervention undertaken to examine the recent failure of the Iodine 129 monitor. The objectives of this intervention have resulted in the scope of the compliance inspection being targeted on issues relevant to understanding the event. This intervention record is therefore complementary to the fact finding intervention. The background to the event and the detailed findings are presented in a separate contact record, they are not replicated here.

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A.  This was not a safety system inspection.

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

I undertook a LC12 compliance inspection within Magnox Reprocessing. It is my opinion that there is no explicit competency assurance and appointment process in place for the subject matter experts that are locally identified and appointed by the facility to provide facility-specific technical advice. Whilst the facility was able to provide verbal assurance of how these were appointed; this was focused upon technical qualifications and length of facility experience, rather than safety case knowledge. It is my opinion that this represents a shortfall against ONR expectations but that it appears to be in line with the licensee’s arrangements. I consider this to be a corporate rather than facility specific issue and I will raise it with the ONR’s Corporate Inspector for Sellafield.

I noted that whilst the responsibilities for decision making within the Duly Authorised Person (DAP) role appeared to be well understood, I found there was inconsistency in the articulation and understanding of the boundaries of decision making, particularly regarding when to seek technical and safety case advice from or to invoke formal decision making processes. No explicit training to support conservative decision making for DAPs was apparent to me.

In addition, I noted that the DAP appointment process does not explicitly examine through observation, the capability of an individual to discharge the control and supervision aspects of the role; relying upon scenario specific interview questions. I was made aware that the licensee has introduced role-specific training and evaluation packages as part of the site level roll-out of the Systematic Approach to Training. I noted that these include guides for control and supervision and Disciplined Operations but was disappointed that this approach has yet to be implemented within Magnox Reprocessing.  I am concerned about the proposed timescales to deliver competency assurance against Relevant Good Practice for these important aspects of the DAP role.

Taking these factors into account, I consider that an IIS rating of 4 (below standard) is appropriate against LC12 ‘Duly Authorised and other Suitably Qualified Persons’.

I undertook a LC26 compliance inspection) within the Magnox Reprocessing Plant. Following discussions with both DAPs in both Shift Team Leader (STL) and Shift Team Co-ordinator (STC) roles, it is my opinion that the extent and form of supervision for operations in the plant control room is variable. In addition, it is my opinion that the role of the STL, particularly with regard to the responsibility for control and supervision and input into decision making, is unclear.  Furthermore, it is my opinion that only a limited amount of structured communication,(for example, face to face shift handover) beyond the Plant Operations Control Centre, takes place between the STC and STLs (both of which are DAPs) and between STCs and the control room operators.

Taking these factors into account, I consider that an IIS rating of 4 (below standard) is appropriate for LC26 ‘Control and Supervision’.

Conclusion of Intervention

It is my recommendation that the licensee considers bringing forward the delivery of the training modules for Control and Supervision and Decision Making for all Magnox Reprocessing DAPs commence as soon as practicable. I have raised a Regulatory Issue to capture and track the resolution of the shortfalls I identified against LC12 and LC26.