Office for Nuclear Regulation

Sellafield - Compliance inspection of Licence Condition 12 (DAPs and SQEPs)

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, 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 12 (duly authorised persons (DAPs) and other suitably qualified and experienced persons (SQEPs). As planned, the intervention focussed on implementation of site arrangements on plant; the arrangements are subject to inspection separately by ONR.

Interventions Carried Out by ONR

LC 12 requires that:

On 13 November 2018, I carried out a planned one-day, on-site LC 12 compliance inspection within the Magnox OU, specifically focussing on the Magnox East River (MER).  The inspection comprised discussions with SL staff, and reviews of plant records and other documentation. A plant visit was also undertaken. 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 LC12 arrangements by management and personnel, as appropriate. Arrangements were implemented to define the qualifications and experience required of appointed DAPs and SQEPs. I also found that DAP appointments 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 a Plant Operations Control Centre (POCC) meeting, DAP handover and maintenance team leader (MTL) pre-job briefs.

Whilst I did not find any specific shortfalls, when inspecting the details in the SQEP role profiles, I noted that prior to November 2017, all training identified was mandatory, whereas, after this date, approximately two-thirds of the training is now specified to be “recommended”.  SL provided an adequate justification in respect of this inspection, however, ONR has a site-wide regulatory issue in relation to training.  I have passed this intelligence to the ONR corporate inspector to consider, as appropriate, and judged that no other formal action is necessary.

From the evidence sampled, I consider that the licensee is compliant with its legal duties under LC12, 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.

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 12 are being implemented adequately. There were no regulatory findings of significance and no follow-up regulatory action is required.