Office for Nuclear Regulation

Planned unannounced compliance inspection covering LC26 - Control and supervision of operations

Executive summary

Purpose of Intervention

In accordance with the Office for Nuclear Regulation (ONR) Sellafield Strategy, each year ONR performs a series of planned compliance inspections of selected licence conditions, targeted at those facilities with significant importance to nuclear safety.  Such inspections can be announced to the duty holder in advance or unannounced where this has benefit in achieving the inspection aim.  In this case I undertook an unannounced inspection as I judged it was important that ONR’s inspectors engaged with a normal planned shift delivering the B204 stack demolition project from their start of day through to shift handover.

ONR gave permission to SL to commence this project on 14 November 2016.  In completing its supporting assessment, ONR recognised the importance of the licensee sustaining adequate control and supervision of this permissioned activity.

Licence condition 26 (control and supervision of operations) does not formally require the licensee to make and implement adequate arrangements. To effectively comply with this condition ONR expects the licensee to have established arrangements or procedures which identify the person(s) responsible for ensuring compliance, and the means by which the licence condition is met.  The aim of this unannounced inspection was to confirm that all B204 stack safety related operations are only carried out under the control and supervision of suitably qualified and experienced personnel.   

Interventions Carried Out by ONR

This planned unannounced compliance inspection against licence condition 26 was undertaken by ONR’s Decommissioning & Remediation site inspector and B204 stack demolition project inspector.

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A as this was not a safety systems inspection.

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

From the inspection sample I found that the B204 stack demolition project has adequate control and supervision arrangements that identify posts to which persons are appointed to carry out and supervise operations affecting safety; and to ensure persons appointed to control and supervise those operations are suitably qualified and experienced.  By observing two shift briefs and engagement with role holders in the project’s command and control structure, I gained confidence that operations that may affect safety are carried out under the control and supervision of suitably qualified and experienced persons. My judgement was reinforced by observing separate Sellafield duly authorised person and construction co-ordinator handover briefs.  I also observed the Sellafield construction co-ordinator’s oversight of the contractor’s supervisors and operatives.  From this sample I was satisfied that contractors are being adequately controlled and supervised.  I noted adequate procedural use and adherence, with only minor improvements to the auditability of check sheet signatures; training matrix; and SCP access control identified.  As a result a level 4 regulatory issue was raised to track completion of these minor improvements.

Conclusion of Intervention

Notwithstanding the minor shortfalls identified, I judge that, on the basis of evidence sampled at the time of this inspection, the licensee has adequately implemented arrangements and procedures which identify the person(s) responsible for ensuring control and supervision.  I therefore consider that the required standard was met and an inspection rating of Green (No Formal Action) is merited.