Office for Nuclear Regulation

Licence Condition 26 Inspection of Pile Fuel Storage Pond Operations

Executive summary

Purpose of intervention

This intervention was undertaken on 4 December 2014 at the Sellafield Limited (SL) nuclear licensed site in Cumbria.

Inspection of Licence Condition (LC) compliance at nuclear licensed sites is an important aspect of ONR’s activities. ONR has defined a programme of system inspections and LC compliance inspections, which focus on the aspects of Sellafield Limited’s operations that are most important to safety and legal compliance. This inspection is identified on ONR’s PP3 inspection plan which covers Sellafield Limited’s Decommissioning Division.

The inspection looked at the site’s control and supervision arrangements and how these are applied to operations on the Sellafield Pile Fuel Storage Pond (PFSP).  This topic was selected for inspection in view of the importance of good control and supervision to nuclear safety at PFSP.

Interventions Carried Out by ONR

I carried out an inspection of the Licensee’s arrangements for compliance with Licence Condition 26 in the Decommissioning Division. LC26 requires the licensee to ensure that no operations are carried except under the control and supervision of suitably qualified and experienced persons appointed for that purpose by the licensee.

My inspection was carried out against the requirements of LC26 and ONR’s associated inspection guidance as defined in NS-INSP-GD-026.  The inspection comprised office-based examination of procedures and records, physical inspection on the plant and interviews with staff. The intervention was undertaken by the Site Inspector supported by an ONR Human Factors Specialist Inspector.

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A – This was not a Systems Based Inspection.

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

I inspected the arrangements for compliance with LC26. The top level site arrangements for compliance with LC26 are defined in SL’s Control and Supervision Manual. I found that this manual contained some ambiguities, e.g. stating that SL achieves compliance to LC26 ‘by appointing those that control and supervise operations which may affect safety as Duly Authorised Persons (DAPs)’, but also that ‘Supervision is performed by SQEP Team Leaders…’.

SL has linked the requirements of LC26 to those of LC12 (Duly Authorised and other Suitably Qualified and Experienced Persons) through the appointment of DAPs to carry out control and supervision, but has left references to Team Leaders also providing supervision within its arrangements. On PFSP I found that team leaders are providing most of the frontline supervision, but their associated Shift Team Leader (STL) role statement does not include control and supervision of operations and there is no supervision training required for the role. This was stated to be common practice in other facilities at the site.

On PFSP the STLs sampled had not received any formal supervisory training. PFSP was therefore not able to describe how competency in control and supervision was assured for team leaders. Nevertheless, through discussion with STMs/STLs, I was able to gain confidence that the principles of control and supervision were well understood by those discharging these functions on PFSP.  PFSP agreed that its STLs would complete the supervision modules of SL’s DAP process and the findings would be discussed with the process owner. Following this inspection, discussions have taken place between ONR and SL on these findings. The Licensee believed its arrangements met ONR expectations, but has agreed to review these arrangements in light of my findings and engage further with ONR to close-out the issue.

I reviewed the arrangements for identifying the level of control and supervision necessary for individual operations. SL demonstrated that a systematic process was in place to:

Examples of task risk assessments and resulting plant instructions were reviewed, and these demonstrated that the level of control and supervision had been assessed and tailored to the risks associated with the specific task. I was satisfied that these arrangements to define the level of supervision required were adequate

During the plant inspection I observed a shift handover between STMs and judged this to be at a good standard, providing a robust handover and transfer of key information, plant status and priorities.

During my inspection on the plant I sampled operational records. Here I identified a number of discrepancies in the consistency and completeness of pre-job briefs and compliance record sheets. SL agreed to raise a condition report to investigate these shortfalls and to provide further information on the causes and solutions to address these.

Conclusion of Intervention

Overall I judged the licensee’s compliance with LC26 to meet IIS rating of 5 (significantly below standard). This was due to a lack of clarity in which roles are appointed to control and supervise operations, and SL being unable to demonstrate the suitable qualification and experience of team leaders to control and supervise operations. SL has agreed that these findings are an accurate record of the inspection findings but have expressed concern over the rating; however this is governed by ONR’s IIS rating system which dictates a rating of 5 where one or more important requirements have been missed and the licensee did not recognise this shortfall prior to this inspection.

I was nevertheless able to gain confidence that the principles of control and supervision were understood by those discharging the function on PFSP and so no immediate safety concerns were evident on the plant.

The findings have been added to the ONR Regulatory Issues database to track further engagement with SL in addressing these issues.