Executive summary
Date(s) of inspection: August 2024
Aim of inspection
In accordance with the Office for Nuclear Regulation’s (ONR’s) Sellafield Strategy, each year ONR performs a series of planned inspections to seek assurance of compliance against selected licence conditions, targeted at those facilities with significant importance to nuclear safety. One such inspection was undertaken at Special Nuclear Materials Value Stream (SNM) South facilities within the Sellafield site in West Cumbria to sample evidence of implementation of Sellafield Limited's arrangements for compliance with Licence Condition (LC) 10 (Training), 12 (Duly authorised and other suitably qualified and experienced persons), 24 (Operating instructions) and 26 (Control and supervision of operations)in order to inform a regulatory judgement regarding the licensee’s compliance with its legal duties under the nuclear site licence.
Subject(s) of inspection
- LC10 - Training - Rating: Green
- LC12 - Duly authorised and other suitably qualified and experienced persons - Rating: Green
- LC24 - Operating instructions - Rating: Green
- LC26 - Control and supervision of operations - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
The inspection was undertaken between the 6 and 8 August 2024 by the Special Nuclear Materials (SNM) site inspector and supported by two Leadership and Management for Safety (LMfS) specialist inspectors and the programme manager for Sellafield Operations.
The inspection involved a planning phase and a site visit, which comprised discussions with Sellafield Limited personnel, the observation of key meetings related to the control of operations, a review of a targeted sample of Sellafield Limited’s documentation and observation of two plant activities.
From a mixture of sampling records, interviewing Sellafield Limited personnel and facility visits, I concluded the following:
No significant matters were identified that required immediate regulatory attention.
For LC10, SNM South provided me with assurance that has an adequate training programme with an adequate oversight. I sampled training records for selected SNM South personnel rostered for duty at the time of the inspection, as well as several SQEP roles related to the implementation of the corporate arrangements for the Management Safety Committee (MSC) and I found that all required training was in date for the personnel sampled.
For LC12, I sampled the SQEP Role Authorisation Records, Certificates of Appointment, and, where appropriate, the completed Generic Assessment Standard (GAS) files for the rostered duty Duly Authorised Persons (DAPs) and the Maintenance Appointed SQEPs (ASQEPs). I found that for the three DAPs sampled (out of seven), that the Certificates of Appointment had been signed by someone other than the Head of Operations.I judged it proportionate to raise a Level 4 Regulatory Issue (RI-12170) to address this minor administrative shortfall against the licensee’s corporate arrangements for LC12.
For LC24, I was satisfied with SNM's South implementation of the corporate arrangements for LC24 in relation to Operator Instructions. I found a minor anomaly in relation to those Category 2 Maintenance Instructions in the Integrated Document Management System (IDMS) format. I note that this issue affects facilities outside the SNM Value Stream and this matter will be raised at a corporate level with the Engineering and Maintenance profession and the Operational Capability and Integration LC24 Process Lead.
For LC26, I sampled the Control and Supervision Organisation Baseline and the Minimum Safe Manning Level (MSML) and found that the documents had completed due process at properly constituted meetings of the local MSC. However, I identified some minor anomalies relevant to the production of the MSML for FL6, and the outstanding MSC recommendation to combine the MSML papers for SPRS and FL6. I therefore judged it appropriate to raise a Level 4 Regulatory Issue (RI-12171) to address this minor administrative shortfall against the licensee’s corporate arrangements for LC26.
I sampled a number of open Operational and Conservative Decision Making (ODM/ CDM) and noted that two CDMs and three ODMs were overdue the maximum live times of one and six months respectively. I therefore judged it appropriate to raise a Level 4 Regulatory Issue (RI-12172) to ensure all ODM and CDMs are progressed and closed in a timely manner.
I observed the daily Plant Operational Control Centre (POCC), DAPs handover and the control and supervision of two activities and overall found an adequate level of planning of activities, DAP handover and control and supervision of those activities sampled.
Conclusion
No matters were identified as requiring immediate regulatory attention.
Based on the evidence sampled at the time of the inspection, I found that, on balance, SNM South is broadly compliant with the licensee’s corporate arrangements for LCs 10, 12, 24 and 26. I therefore judge that SNM South has adequately implemented the licensee’s corporate arrangements made for compliance with the Nuclear Site Licence, with only minor shortfalls identified in relation to LCs 12 and 26.
In relation to the IDMS Maintenance Instructions, I intend to raise the issues identified at a future corporate Operational Capability and Integration Level 4 meeting with the Engineering and Maintenance profession and the Operational Capability and Integration LC24 Process Lead.
Taking all of the above into account, and noting the ONR guidance on inspection ratings, it is my opinion that, on balance, a provisional inspection rating of Green (i.e. no formal action) for each of Licence Conditions 10, 12, 24 and 26 is merited.
I intend to raise three Level 4 (i.e. lowest level) regulatory issues to allow ONR to monitor progress in addressing the identified minor shortfalls.