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, Decommissioning, Fuel and Waste (SDFW) Division. In accordance with that strategy, a Licence Condition (LC) compliance inspection of the Special Nuclear Materials Operating Unit (SNM OU) was carried out, as planned in February 2019.
The purpose of this planned inspection was for ONR to determine the adequacy of implementation of the licensee’s formal arrangements for compliance with LC10 (Training). For the inspection, I focused on the evidence for compliance within the Special Nuclear Material (North) (SNM (N)) facility.
On 28 February 2019, I, the site inspector for the SNM OU, undertook a planned Licence Condition 10 (LC10) inspection within the SNM (N) facility.
The inspection comprised discussions with SL personnel, and reviews of SL records and documents.
LC 10 requires SL to make and implement adequate arrangements for suitable training for all those on site who have responsibility for any operations which may affect safety. As part of my preparation for the delivery of this intervention, the following formal ONR guidance documentation was used:
In addition I also conducted follow up enquires into a recent event which occurred in SNM (N) and reported under INF1 2019/38.
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.
During my inspection I sampled evidence associated with the licensee’s compliance for training of all those in SNM (N) who have responsibility for any operations which may affect safety. I sampled various Sellafield records and documentation and I judged that, on the evidence sampled, the licensee had implemented adequately their processes for compliance with LC10.
From the inspection sample I have seen evidence that SNM (N) is maintaining local arrangements, and in addition to that they have put in place an improvement programme for staff training requirements. SNM (N) also demonstrated a clear plan of how improvements in training will be cascaded to SNM(S).
SNM (N) has also developed a detailed plan for how they will manage their training arrangements going forward through a training committee. SNM (N) provided evidence of work the committee has already completed around improvements to SQEP packs.
SNM (N) also provided evidence to support the work they have completed around job training analysis. SNM (N) has carried out an in depth analyse of certain roles to identify what the training gaps are.
SNM (N) has demonstrated they are not only maintaining their compliance arrangements but undertaking a programme of improvement in respect of its Systematic Approach to Training (SAT) across SNM OU.
There were no significant findings identified during my inspection, and I have not raised any associated Regulatory Issues.
I am of the opinion that SL, as the licensee, has adequately implemented its arrangements for compliance with License Condition 10.
INF1 2019/ 38 follow up - I judged that the potential consequences from this failure of the ventilation system would not result in potential significant harm to a worker or the member of the public, provided that no intrusive operations were ongoing.
As a result of my follow up enquiries on the event reported under INF1 2019/38, I am satisfied that SL are taking the appropriate actions to address any learning and that the events do not meet the ONR formal investigation criteria.
The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.
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 10 are being implemented adequately.
My findings were shared with and accepted by the licensee as part of normal inspection feedback. I have not raised any Regulatory Issues as a result of this inspection.