In accordance with our Sellafield Strategy, ONR undertakes a five year rolling programme of licence condition arrangements inspections. This inspection was performed to assess Sellafield Ltd’s (SL’s) site-wide arrangements for compliance with Licence Condition 26 (Control and Supervision of Operations).
LC26 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.
ONR carried out a 3-day inspection between 25 – 27 February 2015 utilising specialists from the following technical disciplines:
This intervention consisted of a review of SL arrangements for LC26, along with sampling of supporting processes and procedures. In addition I inspected how SL’s LC26 arrangements are being implemented at the following Sellafield facilities:
The following assessment guidance was utilised during this inspection:
N/A. This was not a safety system inspection.
I consider that the processes and procedures SL has in place to support the control element of LC26 are generally robust and of good quality. However I consider that the arrangements for supervision under LC26 are inconsistently implemented across the site.
Under SL’s arrangements, Duly Authorised Persons (DAPs) are responsible for control and supervision of nuclear safety activities. However we observed several instances where this responsibility was being discharged by Team Leaders (i.e. persons who are not DAPs and do not appear to have the equivalent training in control and supervision).
Furthermore, SL’s arrangements for the control and supervision of contractors state that contractors are responsible for the supervision of their own personnel. Following review of the applicable Suitably Qualified and Experienced Person (SQEP) role assessment specification for a contract supervisor, I concluded that the training of such supervisors appeared to be focused around conventional health and safety supervision, with little guidance on nuclear safety supervision or disciplined operations/maintenance standards etc.
I consider this to be a significant shortfall: Where contract staff are supervising work which if done by SL staff, would require supervision by a DAP or suitably SQEP Team Leader then their training and authorisation should be comparable with the arrangements made for SL staff.
Overall, I consider that that an IIS rating of 4 (Below Standard) is appropriate. While I consider that SL has adequate control and supervision arrangements in general, there are specific weaknesses in application. In particular, SL cannot demonstrate competency assurance for all those carrying out control and supervision of operations affecting safety who are not appointed DAPs.
I have raised appropriate Regulatory Issues to capture these findings and will use these to track my findings to resolution.