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ONR Cross-sites Criticality Inspection Series

Dr Adam Nichols CPhys CRadP

WPC Webinar, November 2023

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Contents

I’ll be talking about:

The ONR and what we do;
The rationale for a cross-sites criticality inspection series;
The aims and format of the series;
The sites inspected; and
Generalised conclusions – good practice and areas for improvement.

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The ONR and what we do (1)

Office for Nuclear Regulation: UK’s independent nuclear regulator.
Legal authority to regulate nuclear safety, civil nuclear security, safeguards and conventional health and safety across 35 nuclear licensed sites. Includes operating reactors (AGRs + 1 PWR), fuel cycle facilities, waste management and decommissioning sites, as well as other licensed and, in part, authorised defence sites.
Regulation of design and construction of new nuclear facilities.
Regulation of transport of civil nuclear and radioactive material by road, rail and inland waterway (with delegations for sea and air).

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The ONR and what we do (2)

Approval of security arrangements within civil nuclear, and provides regulatory oversight for the security of transport of civil nuclear materials and management of effective arrangements for sensitive nuclear information.
Nuclear safeguards, ensuring civil nuclear material remains accounted for and controlled to ensure the UK maintains its safeguards obligations.
Mission: To protect society by securing safe nuclear operations.
Vision: To be a modern, transparent regulator delivering trusted outcomes and value.
Values: Accountable, Open-minded, Fair, Supportive.

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ONR – How we regulate

Permissioning inspection (incl. assessment).
Compliance inspection.
Enforcement.
Influence.

ONR is made up of site inspectors and specialist inspectors drawn from various professional fields (e.g., criticality).

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Permissioning inspection: Before ONR can permission key activities, we assess licensees safety cases, on a sample basis according to potential consequences, to ensure that the hazards have been understood and are properly controlled.

Compliance inspection: We check that licensees comply with their licence conditions through planned inspections, on a sample basis according to information derived from safety cases and other operational intelligence.

Enforcement: We undertake the full spectrum of enforcement activities, from the provision of advice through to prosecution, in accordance with ONR's Enforcement Policy Statement and the Regulators Compliance Code.

Influence: We seek to use our influence to gain improvements in areas which are difficult to regulate such as safety culture, leadership and vision.

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Cross-sites inspections series – what is it?

ONR sometimes seeks to inspect themes across a broad cross-section of industry dutyholders (i.e., a compliance inspection replicated across multiple licensed sites).
Such “cross-sites” inspections focus on particular areas (e.g., management of criticality safety), with consistent formats and objectives across the dutyholders inspected.
This allows ONR to identify common deficiencies and areas of good practice, sharing these with the industry to influence improvements.
It also allows ONR to gauge the ‘health’ of a particular area across the industry.

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Why do a cross-sites criticality inspections series?

ONR last did a cross-sites inspection series focussing on criticality in 2009-2011.

Proportionate to revisit given the evolution of industry (increasing fragmentation, diminishing personnel levels).

Allows ONR to sample a broad cross-section of dutyholders.

Ascertains how dutyholders are managing criticality safety.

‘Deep slice’ sampling methodology.

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Aims of the inspection series

To identify deficiencies in the dutyholder’s management of criticality safety (and/or non-compliances) and to work with dutyholders to ensure prompt, sustained rectification.
To identify/share areas of good practice.
To influence improvements.
To maintain consistency of regulation.
To drive improvements to ONR Technical Inspection Guide: NS-INSP-GD-053 - Criticality Safety (onr.org.uk).
To develop inspectors.

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Licence conditions covered by the inspection series

ONR - Licence Condition Handbook
LC 8 (Warning Notices)
LC 10 (Training)
LC 12 (Duly Authorised and Other Suitably Qualified and Experienced Persons)
LC 23 (Operating Rules)
LC 24 (Operating Instructions)
LC 28 (Examination, Inspection, Maintenance and Testing)
(For a subset of sites) - LC 36 (Organisational Capability)

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In order to assure the safety of nuclear installations in the UK, ONR works on a system of regulatory control based on a robust licensing process by which a corporate body is granted a licence to use a site for specified activities.

The nuclear site licence granted by ONR is a legal document, issued for the full life cycle of the facility. It contains site-specific information, such as the licensee's address and the location of the site, and defines the number and type of installations permitted. Such installations include nuclear power stations, research reactors, nuclear fuel manufacturing and reprocessing, and the storage of radioactive matter in bulk.

A set of 36 Standard Conditions, covering design, construction, operation and decommissioning, is also attached to each licence. These conditions require licensees to implement adequate arrangements to ensure compliance.

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Format of the inspection series

Conducted by two criticality specialist inspectors.
Standard question set (issued in advance) – from TIG.
Consistent approach across dutyholders, albeit with some cross-site variation.
Discussions with dutyholder personnel, sampling of documentation, walkdown of plant.

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The sites covered – August 2021 to April 2022

Springfields - Springfields Fuels Ltd

Capenhurst – Urenco UK Ltd

Dounreay - Dounreay Site Restoration Ltd

Raynesway – Rolls Royce Submarines Ltd

Hunterston B - EDF Nuclear Generation Ltd

Hartlepool – EDF Nuclear Generation Ltd

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The question set – ONR’s Technical Inspection Guide

ONR’s criticality TIG: NS-INSP-GD-053 - Criticality Safety (onr.org.uk).

Appendices contain questions pertinent to those Licence Conditions which ONR feels are of greatest relevance to criticality safety.

ONR GUIDE

CRITICALITY SAFETY

Document Type:

Nuclear Safety Technical Inspection Guide

Unique Document ID and Revision No:

NS-INSP-GD-053 Revision 6

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ONR GUIDE
CRITICALITY SAFETY
Document Type:	Nuclear Safety Technical Inspection Guide
Unique Document ID and Revision No:	NS-INSP-GD-053 Revision 6

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Typical inspection

Day 1:

Walk-down of key plant.
LC 8.
LC 10/12.
LC 23/24.

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Day 2:

Summary of Day 1.
Complete LC 23/24.
LC 28.
Hot feedback.

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Findings – good practice examples

Use of audit spreadsheets for maintaining criticality safety notices on plant (including location, issue, dates, etc.)

Protection of warning notices behind screens (to avoid damage or operational graffiti).

Alignment to Working Party on Criticality competency expectations.

Succession planning.

Calculation cross-checks.

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Transparency of Operating Rules.

Engineering reinforcing operational safety requirements relying on human agency.

Comprehensive criticality safety training for both general awareness and ‘Suitably Qualified and Experienced’ (SQEP) / ‘Duly Authorised Person’ roles, including refreshers.

Knowledge management and capture.

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Findings – areas for improvement

Age profile of in-post experienced assessors and limited new personnel.
Developing and maintaining adequate criticality SQEP resource in face of change of operational focus.
Standard UK definition of what constitutes a competent criticality assessor.
Unresolved (sometimes defunct) ‘defect tags’ on pieces of equipment and other maintenance issues.

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Development of inspectors

Less experienced inspectors gained experience in active inspection.

Less experienced inspectors supported senior inspectors, and then led a further inspection themselves with a senior inspector supporting.

Provided exposure of graduates and degree apprentices to ONR’s front-line work (as observers).

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Recommendations

A presentation be prepared summarising the key findings of this set of inspections and should be delivered by ONR to both the UK WPC and to a global audience at the International Conference on Nuclear Criticality (ICNC) in 2023 in Japan.
ONR criticality specialist inspectors continue to engage with the UK Working Party on Criticality, to support the development of strengthened guidance.
ONR criticality specialist inspectors continue to engage with the UK WPC, Safety Directors Forum etc. to understand the extent of the resource issue more fully. This will raise awareness across the industry of the current shortage of criticality specialist resource and encourage development of an industry-wide initiative to increase the number of people coming into the criticality safety specialism.

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General conclusions

No matters of legal non-compliance.

Adequate and fairly uniform standard of safety management across dutyholders.

Good practice (anonymised!) will be shared with industry via WPC.

Areas for improvement (anonymised!) will be shared via WPC.

Upgraded TIG has now been used ‘in the field’ – positive feedback received.

Developed regulatory skill-set of less experienced ONR inspectors and gave development opportunities to ONR-sponsored graduates and degree apprentices.

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Moving forward…

Assessment report pulling together key, tracked recommendations (complete).

Feedback to industry (WPC, conferences).

Influencing improvements in industry.

Enabling regulation.

Further improvements to TIG.

Further development opportunities for inspectors.

Cross-sites radiation shielding inspection being drafted based on this series.

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