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