Transcript Slide 1
Operator Performance Appraisal Byron Tilly RS Unit Manager, SEPA Purpose & Scope of OPA SEPA is required to direct resources to where they are most needed SEPA has adopted a risk-based assessment methodology to determine inspection frequencies System used for RSA premises is the Operator Performance Assessment - OPA OPA assesses and scores the performance of operators in managing the hazards to the environment from licensed activities Purpose & Scope of OPA Methodology for undertaking OPAs is intended to: Be objective whilst recognising need for professional judgement of officers Provide a numerical indicator to enable SEPA to prioritise its inspections and focus its resources Note – The OPA is not intended to be used as a substitute for production of inspection reports or taking appropriate enforcement action Purpose & Scope of OPA Objective of the OPA scoring scheme: To identify sites which are poor performers To allow regulatory effort to be targeted appropriately The RSA OPA scheme is an internal guide for SEPA to focus its inspections and target resources Attributes to be assessed 1. Radioactive Substance Security Physical security of the radioactive substances with regard to inadvertent loss or theft from the premises Physical means by which the operator is able to restrict access to radioactive substances by authorised persons only Attributes to be assessed 2. Knowledge & Implementation of Licence Requirements Operators fundamental understanding of the certificates, the regulations and relevant duties to apply BPM Effectiveness of implementing the certificates’ and regulatory requirements Attributes to be assessed 3. Recording and Use of Information Operator would be expected to keep accurate records of the types, volumes and activities of all wastes accumulated and disposed of from the premises Records should be kept upto date and utilised to demonstrate compliance Attributes to be assessed 4. Facility Management Physical state of the facility and the management of maintenance activities Reactive approach to maintenance? Proactive work undertaken to predict and prevent future breakdowns or remediate deteriorating facilities? The operator should have a rationalised and documented approach to determining maintenance strategy Attributes to be assessed 5. Radioactive Substance Management Effectiveness of the radioactive substance management system, including written procedures Effectiveness and extent of implementation of operating procedures Control of RS operations Attributes to be assessed 6. Incidents, Complaints & Non-Compliance Events Overall compliance with licence requirements Incidents & complaints Non-compliances SEPA’s improvement requirements and the operator’s response to such requirements Scoring of Attributes Each of the 6 attributes is given a score out of 5 Scoring System 1 - Very few or no features within an attribute complied with 2 – Minority of features complied with or a significant failure observed 3 – Majority of the features complied with and no significant failures observed 4 – Nearly all features complied with and no significant failures observed 5 – All features complied with and no significant failures observed Satisfactory/Unsatisfactory Criteria A score of 3 is considered to be satisfactory and indicates that the operator is compliant with all relevant licence conditions relating to that attribute If the operator scores one level 2 on any attribute, the OPA shall be considered satisfactory provided all other attributes are scored at level 3 or above If two or more attributes are scored at level 2 or below, then the assessment is considered unsatisfactory A score of 1 against any attribute means the overall assessment is unsatisfactory Pass/Fail Mark Once the total score has been calculated, it is necessary to determine if the operator has passed (satisfactory performance) or failed (unsatisfactory performance) the assessment A score of 17 or above indicates a pass mark, with the following caveats: A score of 1 on any attribute Two or more attributes which have scored 2