Office for Nuclear Regulation

Compliance inspection of LC26 and follow-up enquiries on INF1 2018/374

Executive summary

Purpose of Intervention

The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Sellafield site licensee (Sellafield Limited, SL) against a strategy defined by the ONR Sellafield Sub Division. In accordance with that strategy, Licence Condition (LC) compliance inspections were carried out on Calder Hall (CH), as planned. 

The purpose of this inspection was for the ONR to determine the adequacy of implementation of the licensee’s arrangements for compliance with LC 26 (control and supervision of operations). As planned, the intervention was focussed implementation of site arrangements on plant; the arrangements are subject to inspection separately by ONR. SL reorganised CH management of operations in 2017, moving the defuelling operations team to within the Remediation management chain from Spent Fuel Management, with one objective being to make the control structure clearer, the facility itself was already under Remediation management control.

Interventions Carried Out by ONR

LC 26 requires that “the licensee shall 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.”

On 27 June 2018, I carried out a planned one-day, on-site LC 26 compliance inspection at Calder Hall.  The inspection comprised discussions with SL staff, contractors and reviews of plant records plus other documentation.  In carrying out this inspection, the following ONR guidance was used:

Explanation of Judgement if Safety System Not Judged to be Adequate

This was not a system based inspection, and therefore no judgement has been made of the adequacy of implementation of any part of the safety case.

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

I found that there was good understanding of the implementation of LC26 arrangements by management and personnel, as appropriate. Arrangements were implemented to define posts for the control and supervision of operations and the qualifications and experience required of appointed suitably qualified and experienced persons (ASQEPs). I also found that appointments of Duly Authorised Persons (DAPs under LC12) and SQEPs under LC26 are formally recorded.

There was a good understanding by personnel of the concepts of control and supervision at the plant level, and how this is carried out on a daily basis. This was tested by discussions with DAPs and Suitably Qualified and Experienced Persons (SQEPs), observation of Plant Operations Control Centre (POCC) meeting, DAP handover and maintenance team leader (MTL) pre-job briefs.

Whilst I did not find any safety shortfalls in the arrangements for control and supervision of contractors, nor in the implementation of those arrangements of work control through the safe systems of work controller’s office; I did judge that the contractor sampled in the inspection did not clearly articulate the differences in roles between the reactor plant DAP (responsible overall for nuclear safety at Calder Hall) and the fuel route DAP (responsible for refuelling operations with associated plant and present in the area where the contractor was undertaking work).  I judged that the SL internal regulator can address this minor observation and I will follow up through routine engagements with the internal regulator, as necessary.  I judged that no regulatory issue is warranted.

From the evidence sampled, I consider that the licensee is compliant with its legal duties under LC26, and that there were limited opportunities for further ALARP improvements identified.  Therefore, it is my opinion that an inspection rating of Green (no formal action) is merited against both licence conditions.

From those areas sampled, I did not identify any significant shortfalls in the licensee’s formal arrangements for compliance which would prompt a further inspection of those arrangements earlier than currently planned. 

Conclusion of Intervention

From the evidence sampled during this inspection, I judge that there was sufficient evidence that the licensee’s formal arrangements for compliance with Licence Condition 26 are being implemented adequately. There were no regulatory findings of significance and no follow-up regulatory action is required.