Executive summary
Date(s) of inspection
- September 2023
Aim of inspection
The Office for Nuclear Regulation (ONR) undertakes all its regulatory interactions with the Sellafield site licensee, Sellafield Limited, against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. In accordance with this strategy a planned Corporate Licence Condition Inspection (CLCI), targeted at Sellafield Limited’s site-wide corporate arrangements for compliance with Licence Condition 10 (LC10) “Training” and their implementation, was undertaken 5-6 September 2023.
In addition to the inspection of Sellafield Limited’s site-wide LC10 arrangements and the site-wide implementation of these a specific additional aim of this inspection was to contribute to a wider ONR response to Sellafield being assigned a rating of Enhanced Regulatory Attention for the “Capable Organisation” supporting indicator within ONR’s framework for deciding on the regulatory attention (for safety) for licensed sites. [Information on regulatory attention is reported in the “Chief Nuclear Inspector’s annual report on Great Britain’s nuclear industry”]. In this context, this inspection specifically targeted the capability of Sellafield Limited’s training function to deliver safety related training estimated to be needed over the next three years.
Subject(s) of inspection
- LC10 – Training – Rating: Green
Key findings, inspector’s opinions and reasons for judgement made
The Office for Nuclear Regulation (ONR) undertakes all its regulatory interactions with the Sellafield site licensee, Sellafield Limited, against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. In accordance with this strategy a planned Corporate Licence Condition Inspection (CLCI), targeted at Sellafield Limited’s site-wide corporate arrangements for compliance with Licence Condition 10 (LC10) “Training” and their implementation, was undertaken 5-6 September 2023.
In addition to the inspection of Sellafield Limited’s site-wide LC10 arrangements and the site-wide implementation of these, a specific additional aim of this inspection was to contribute to a wider ONR response to Sellafield being assigned a rating of Enhanced Regulatory Attention for the “Capable Organisation” supporting indicator within ONR’s framework for deciding on the regulatory attention (for safety) for licensed sites. [Information on regulatory attention is reported in the “Chief Nuclear Inspector’s annual report on Great Britain’s nuclear industry”.] In this context, this inspection specifically targeted the capability of Sellafield Limited’s training function to deliver safety related training estimated to be needed over the next three years.
The specific objectives of this inspection were to determine the adequacy, judged against ONR’s expectations, of:
a. Sellafield Limited’s site-wide corporate arrangements made to comply with LC10;
b. The interfaces between Sellafield Limited’s site-wide corporate arrangements made to comply with LC10 and particularly relevant other Licence Conditions (LCs);
c. Sellafield Limited’s organisational capability related to LC10, which included specific consideration of the capability of Sellafield Limited’s training function to deliver safety related training estimated to be needed over the next three years;
d. Experience and training of selected persons assigned responsibility under Sellafield Limited’s site-wide corporate arrangements to address the requirements of LC10;
e. Records [Licence Condition 6 (LC6) “Documents, records, authorities and certificates” refers] made to demonstrate compliance with LC10;
f. Sellafield Limited’s means of gaining internal assurance of compliance with LC10 and learning from incidents related to LC10; and,
g. Implementation on a sampling basis of Sellafield Limited’s site-wide corporate arrangements to address the requirements of LC10.
This inspection was led by a Sellafield Corporate Site Inspector with support from a Leadership and Management for Safety Inspector and a Human Factors Inspector. Henceforth, the use of the pronoun “we” refers to this team whilst the pronoun “I” refers to the Sellafield Corporate Site Inspector.
We undertook a desktop review of documentation prior to the inspection, and this was followed by a face-to-face inspection with members of the Sellafield Limited training function.
We consider that the engagement prior to and during this inspection has allowed a meaningful CLCI of LC10 to be completed which met all the objectives described above.
Key findings and judgements made are recorded separately in relation to the following areas:
a. The overall inspection;
b. Licence Condition 10; and,
c. Capable Organisation regulatory attention indicator.
The Overall Inspection
We identified the following observations as areas of good practice relating to delivery of the overall inspection:
a. Prompt delivery of the information requested prior to and during the inspection;
b. Preparation for the inspection; and,
c. Open, honest and helpful discussions and those persons involved were knowledgeable and receptive to challenge.
Licence Condition 10
Sellafield Limited delivers training through a de-centralised training organisation that includes Central Training, Enterprise Facility Training and training for Key Professions. We have used the terms “overall training needs” and “overall training capability” to describe the total site‑wide training needs and the total Sellafield Limited training capability, which is the sum of the training capabilities across Central Training, Enterprise Facility Training etc.
On the basis of the evidence sampled before and during this inspection we identified the following observations as areas of good practice relating to Sellafield Limited’s LC10 arrangements and/ or their implementation:
a. Development and application of a systematic process to estimate overall training needs and hence the required overall training capability both now and going forwards over future years;
b. Current gaps in the required overall training capability are well understood and realistic plans are in place to fill these gaps;
c. An established business process improvement technique has been systematically used to inform the Training Improvement Programme;
d. Effective use has been made of the governance forums for training, with numerous examples of collaboration and challenge; and,
e. The training function has developed a risk-based assurance programme in line with Sellafield Limited guidance and provided valuable support to duty holders during the development of their assurance programmes.
On the basis of the evidence sampled before and during this inspection we provided the following regulatory advice relating to Sellafield Limited’s LC10 arrangements and/ or their implementation. Sellafield Limited to consider:
a. Reviewing how it demonstrates that it meets training obligations related to nuclear security, nuclear safeguards and transport (of radioactive materials);
b. Putting in place guidance to help ensure consistent and reliable inputs from many stakeholders/ areas required to achieve good quality estimates of overall training needs and overall training capability;
c. Reviewing, and if necessary revising, the current required overall training capability to reflect the increased workload resulting from the strengthening of training team engagement in Sellafield Limited’s modifications process; and,
d. Undertaking similar reviews, and if necessary revisions, of the current required overall training capability for future process changes.
On the basis of the evidence sampled before and during this inspection we did not identify any regulatory findings, representing shortfalls against relevant regulatory guidance.
Based on this I considered that an Inspection Rating of Green (No Formal Action) for LC10 was appropriate, noting the relevant guidance within ONR documentation.
The Sellafield Limited personnel present at the hot debrief were in broad agreement with the outcomes of this inspection.
Capable Organisation Regulatory Attention Indicator
a. Given the assumptions in the Sellafield Operating Plan, reasonable estimates are being made of overall training needs and hence required overall training capability both now and going forwards over future years;
b. Evidence has been provided of increased resource requirements for training aligned to future capital projects; and,
c. Evidence has been provided of enhanced recruitment to the training organisation to balance increased site-wide attrition.
Conclusion
On the basis of the evidence sampled before and during this inspection, we identified no regulatory findings representing gaps against relevant good practice.
Based on this, I considered that an Inspection Rating of Green (No Formal Action) for LC10 was appropriate, noting the relevant guidance within ONR documentation.