Executive summary
Date(s) of inspection: October 2023
Aim of inspection
The Office for Nuclear Regulation (ONR) undertakes all its regulatory interactions with the Sellafield site licensee, Sellafield Limited, against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. In accordance with this strategy, this was a planned Corporate Licence Condition Inspection (CLCI) of Licence Condition 10 (LC10) “Training” and Licence Condition 12 (LC12) “Duly authorised and other suitably qualified and experienced persons”. In relation to Sellafield Limited’s updated safety case process, this inspection was targeted at training and demonstration that that training supports staff in becoming Suitably Qualified and Experienced Persons (SQEPs) in relation to safety case production.
Updated safety case process training and demonstration that those trained are SQEPs were targeted for the following reasons:
a. To contribute to a wider ONR response to Sellafield being assigned a rating of Enhanced Regulatory Attention for the “Nuclear safety case adequacy and currency” supporting indicator within ONR’s framework for deciding on the regulatory attention (for safety) for licensed sites. [Information on regulatory attention is reported in the “Chief Nuclear Inspector’s annual report on Great Britain’s nuclear industry”].
b. To enable close out of the final open action associated with Regulatory Issue (RI)-10473 “Sellafield LC14 Intervention - Detailed Matters Related to Safety Cases Arrangements (Site-Wide)” raised following a CLCI of Licence Condition 14 (LC14) “Safety documentation” in November 2021 (ONR-SDFW-IR-21-127, 2021/88228). The relevant action is RI-10473 Action 02 “The Sellafield Limited safety cases team to update training and competency documents to reflect the updated safety case arrangements”.
To support this inspection, on 1 August 2023 two members of the ONR inspection team observed (ONR Contact Record ONR-SDFW-CR-23-285, 2023/45858) a training session structured around implementation of Sellafield Limited Practice (SLP) 2.17.02 Issue 5, June 2022, “How do I Develop a Nuclear Safety Case?” (2023/26244). Observations during this course and assessment are included within the Inspection Record for this inspection.
Updated safety case process training and demonstration that those trained are SQEPs were targeted for the following reasons:
a. To contribute to a wider ONR response to Sellafield being assigned a rating of Enhanced Regulatory Attention for the “Nuclear safety case adequacy and currency” supporting indicator within ONR’s framework for deciding on the regulatory attention (for safety) for licensed sites. [Information on regulatory attention is reported in the “Chief Nuclear Inspector’s annual report on Great Britain’s nuclear industry”].
b. To enable close out of the final open action associated with Regulatory Issue (RI)-10473 “Sellafield LC14 Intervention - Detailed Matters Related to Safety Cases Arrangements (Site-Wide)” raised following a CLCI of Licence Condition 14 (LC14) “Safety documentation” in November 2021 (ONR-SDFW-IR-21-127, 2021/88228). The relevant action is RI-10473 Action 02 “The Sellafield Limited safety cases team to update training and competency documents to reflect the updated safety case arrangements”.
To support this inspection, on 1 August 2023 two members of the ONR inspection team observed (ONR Contact Record ONR-SDFW-CR-23-285, 2023/45858) a training session structured around implementation of Sellafield Limited Practice (SLP) 2.17.02 Issue 5, June 2022, “How do I Develop a Nuclear Safety Case?” (2023/26244). Observations during this course and assessment are included within the Inspection Record for this inspection.
Subject(s) of inspection
- LC10 - Training - Rating: Green
- LC12 - Duly authorised and other suitably qualified and experienced persons - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
The Office for Nuclear Regulation (ONR) undertakes all its regulatory interactions with the Sellafield site licensee, Sellafield Limited, against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. In accordance with this strategy a planned Corporate Licence Condition Inspection (CLCI) of Licence Condition 10 (LC10) “Training” and Licence Condition 12 (LC12) “Duly authorised and other suitably qualified and experienced persons” was undertaken on 19 October 2023. In relation to Sellafield Limited’s updated safety case process, this inspection was targeted at training and demonstration that that training supports staff in becoming Suitably Qualified and Experienced Persons (SQEPs) in relation to safety case production.
Updated safety case process training and demonstration that training supports staff in becoming SQEPs in relation to safety case production were targeted for the following reasons:
a. To contribute to a wider ONR response to Sellafield being assigned a rating of Enhanced Regulatory Attention for the “Nuclear safety case adequacy and currency” supporting indicator within ONR’s framework for deciding on the regulatory attention (for safety) for licensed sites. [Information on regulatory attention is reported in the “Chief Nuclear Inspector’s annual report on Great Britain’s nuclear industry”].
b. To enable close out of the final open action associated with a Regulatory Issue (RI) raised following a CLCI of Licence Condition 14 (LC14) “Safety documentation” in November 2021.
To support this inspection, on 1 August 2023 two members of the ONR inspection team observed a training course “Developing a Safety Case” based on one aspect of Sellafield Limited’s updated safety case process.
In relation to Sellafield Limited’s updated safety case process the objectives of this inspection were to determine, judged against ONR’s expectations, whether or not Sellafield Limited has:
a. Implemented its LC10 arrangements to produce suitable training;
b. Implemented its LC12 arrangements to ensure that only SQEPs fulfil relevant roles;
c. Produced appropriate Licence Condition 6 (LC6) “Documents, records, authorities and certificates” records; and,
d. Produced a plan for the roll out of the remaining training.
This inspection was led by a Sellafield Corporate Site Inspector with support from a Fault Studies Inspector and a Human Factors Inspector. Henceforth, the use of the pronoun “we” refers to this team whilst the pronoun “I” refers to the Sellafield Corporate Site Inspector.
In addition to observing a relevant training course, we undertook a desktop review of documentation prior to the inspection, and this was followed by a face to face inspection with relevant Sellafield Limited personnel.
We consider that the engagement prior to and during the inspection has allowed us to complete a meaningful Corporate Licence Condition Inspection of LC10 and LC12 targeted at Sellafield Limited’s updated safety case process.
Key findings and judgements made are recorded separately in relation to the following areas:
a. The overall inspection;
b. Licence Condition 10 and Licence Condition 12;
c. Nuclear safety case adequacy and currency regulatory attention indicator; and,
d. LC14 Regulatory Issue.
We identified the following observations as areas of good practice relating to delivery of the overall inspection:
a. Delivery of the information requested;
b. Preparation for the inspection; and,
c. Open, honest and helpful discussions and those persons involved were knowledgeable and receptive to challenge.
On the basis of the evidence sampled before and during this inspection we identified the following observations as areas of good practice relating to Sellafield Limited’s LC10 and LC12 arrangements and/ or their implementation:
a. The training observed was delivered in an engaging and interesting manner;
b. Early engagement with the training developers and Subject Matter Experts to ensure all aspects of training are identified;
c. Wide consultation with operations and other areas and with the contractor community to identify who in addition to the safety case profession staff need either training or briefing;
d. The putting in place of a Training Programme Description to help ensure clarity on what is required to be a safety case related SQEP;
e. Implementation of a programme to address legacy safety case related training; and,
f. Good progress in relation to training and demonstration of SQEP is being made in line with realistic plans.
On the basis of the evidence sampled before and during this inspection we provided the following regulatory advice relating to Sellafield Limited’s LC10 and LC12 arrangements and/ or their implementation. Sellafield Limited to consider:
a. When developing training objectives, the wording of enabling objectives to ensure that they meet the terminal objectives and are achievable and measurable; and,
b. Including provision of safety cases training to members of the Human Factors team who are Sellafield Limited employees.
The advice relating to the Human Factors team arose since this team had recently become part of the safety cases profession. The Sellafield Limited Head of Safe Cases committed to taking this advice so a RI was not raised. Since the Human Factors team are also reliant on contractors, consideration should also be given to offering the same opportunity to contractors supporting the Human Factors team.
On the basis of the evidence sampled before and during this inspection we did not identify any regulatory findings, representing shortfalls against relevant regulatory guidance.
Based on this I considered that an Inspection Rating of Green (No Formal Action) for LC10 and for LC12 was appropriate, noting the relevant guidance within ONR documentation.
The Sellafield Limited personnel present at the hot debrief were in broad agreement with the outcomes of this inspection.
Nuclear Safety Case Adequacy and Currency Regulatory Attention Indicator
Sellafield Limited is several years into a multi-year programme to update its safety cases processes and guidance.
In relation to one of the earlier safety cases process updates (to the developing a nuclear safety case process), Sellafield Limited has developed and implemented training and assessment in line with its LC10 and LC12 arrangements.
Plans are in place to roll out further training related to other updated safety cases processes and guidance in line with its LC10 and LC12 arrangements.
This gives confidence that the updated processes and guidance will be properly implemented. This will lead to improvements in nuclear safety case adequacy and currency.
LC14 Regulatory Issue
On the basis of this inspection I will set the final open action associated with the LC14 RI to Complete (as of 19 October 2023) and Close this RI.
Updated safety case process training and demonstration that training supports staff in becoming SQEPs in relation to safety case production were targeted for the following reasons:
a. To contribute to a wider ONR response to Sellafield being assigned a rating of Enhanced Regulatory Attention for the “Nuclear safety case adequacy and currency” supporting indicator within ONR’s framework for deciding on the regulatory attention (for safety) for licensed sites. [Information on regulatory attention is reported in the “Chief Nuclear Inspector’s annual report on Great Britain’s nuclear industry”].
b. To enable close out of the final open action associated with a Regulatory Issue (RI) raised following a CLCI of Licence Condition 14 (LC14) “Safety documentation” in November 2021.
To support this inspection, on 1 August 2023 two members of the ONR inspection team observed a training course “Developing a Safety Case” based on one aspect of Sellafield Limited’s updated safety case process.
In relation to Sellafield Limited’s updated safety case process the objectives of this inspection were to determine, judged against ONR’s expectations, whether or not Sellafield Limited has:
a. Implemented its LC10 arrangements to produce suitable training;
b. Implemented its LC12 arrangements to ensure that only SQEPs fulfil relevant roles;
c. Produced appropriate Licence Condition 6 (LC6) “Documents, records, authorities and certificates” records; and,
d. Produced a plan for the roll out of the remaining training.
This inspection was led by a Sellafield Corporate Site Inspector with support from a Fault Studies Inspector and a Human Factors Inspector. Henceforth, the use of the pronoun “we” refers to this team whilst the pronoun “I” refers to the Sellafield Corporate Site Inspector.
In addition to observing a relevant training course, we undertook a desktop review of documentation prior to the inspection, and this was followed by a face to face inspection with relevant Sellafield Limited personnel.
We consider that the engagement prior to and during the inspection has allowed us to complete a meaningful Corporate Licence Condition Inspection of LC10 and LC12 targeted at Sellafield Limited’s updated safety case process.
Key findings and judgements made are recorded separately in relation to the following areas:
a. The overall inspection;
b. Licence Condition 10 and Licence Condition 12;
c. Nuclear safety case adequacy and currency regulatory attention indicator; and,
d. LC14 Regulatory Issue.
We identified the following observations as areas of good practice relating to delivery of the overall inspection:
a. Delivery of the information requested;
b. Preparation for the inspection; and,
c. Open, honest and helpful discussions and those persons involved were knowledgeable and receptive to challenge.
On the basis of the evidence sampled before and during this inspection we identified the following observations as areas of good practice relating to Sellafield Limited’s LC10 and LC12 arrangements and/ or their implementation:
a. The training observed was delivered in an engaging and interesting manner;
b. Early engagement with the training developers and Subject Matter Experts to ensure all aspects of training are identified;
c. Wide consultation with operations and other areas and with the contractor community to identify who in addition to the safety case profession staff need either training or briefing;
d. The putting in place of a Training Programme Description to help ensure clarity on what is required to be a safety case related SQEP;
e. Implementation of a programme to address legacy safety case related training; and,
f. Good progress in relation to training and demonstration of SQEP is being made in line with realistic plans.
On the basis of the evidence sampled before and during this inspection we provided the following regulatory advice relating to Sellafield Limited’s LC10 and LC12 arrangements and/ or their implementation. Sellafield Limited to consider:
a. When developing training objectives, the wording of enabling objectives to ensure that they meet the terminal objectives and are achievable and measurable; and,
b. Including provision of safety cases training to members of the Human Factors team who are Sellafield Limited employees.
The advice relating to the Human Factors team arose since this team had recently become part of the safety cases profession. The Sellafield Limited Head of Safe Cases committed to taking this advice so a RI was not raised. Since the Human Factors team are also reliant on contractors, consideration should also be given to offering the same opportunity to contractors supporting the Human Factors team.
On the basis of the evidence sampled before and during this inspection we did not identify any regulatory findings, representing shortfalls against relevant regulatory guidance.
Based on this I considered that an Inspection Rating of Green (No Formal Action) for LC10 and for LC12 was appropriate, noting the relevant guidance within ONR documentation.
The Sellafield Limited personnel present at the hot debrief were in broad agreement with the outcomes of this inspection.
Nuclear Safety Case Adequacy and Currency Regulatory Attention Indicator
Sellafield Limited is several years into a multi-year programme to update its safety cases processes and guidance.
In relation to one of the earlier safety cases process updates (to the developing a nuclear safety case process), Sellafield Limited has developed and implemented training and assessment in line with its LC10 and LC12 arrangements.
Plans are in place to roll out further training related to other updated safety cases processes and guidance in line with its LC10 and LC12 arrangements.
This gives confidence that the updated processes and guidance will be properly implemented. This will lead to improvements in nuclear safety case adequacy and currency.
LC14 Regulatory Issue
On the basis of this inspection I will set the final open action associated with the LC14 RI to Complete (as of 19 October 2023) and Close this RI.
Conclusion
On the basis of the evidence sampled before and during this inspection, we identified no regulatory findings representing gaps against relevant good practice.
Based on this, I considered that an Inspection Rating of Green (No Formal Action) for LC10 and LC12 was appropriate, noting the relevant guidance within ONR documentation.
Based on this, I considered that an Inspection Rating of Green (No Formal Action) for LC10 and LC12 was appropriate, noting the relevant guidance within ONR documentation.