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Planned compliance inspection covering Licence Condition 36 (Organisational capability)

  • Site: Sellafield
  • IR number: 19-059
  • Date: July 2019
  • LC numbers: 36

Executive summary

Purpose of Intervention

The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Sellafield site licensee (Sellafield Limited (SL)) against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. The planned inspection schedule for 2019/20 identifies the Licence Conditions (LCs) that will be inspected during this period.

The purpose of this planned inspection was for ONR to determine if SL is adequately implementing the licensee’s site-wide arrangements for compliance with LC 36 (“Organisational capability”) across the Special Nuclear Materials (SNM) North and South facilities. I focused on sampling evidence of compliance in the SNM Value Stream since the provision of adequate human resources is fundamental to the safe operation of these facilities and the delivery of the high hazard and risk reduction work by SL.

The overall adequacy of SL's site-wide LC 36 arrangements is considered separately in other ONR interventions.

Interventions Carried Out by ONR

Licence Condition 36 requires that the licensee provides and maintains adequate financial and human resources to ensure the safe operation of the licensed site.

I carried out a planned LC 36 compliance inspection of the SNM North and South facilities. My inspection focused on:

  • SL’s nuclear baseline for the SNM Value Stream (i.e. the means by which SL demonstrates the adequacy of its organisational structure, staffing and competencies to manage nuclear safety);
  • The change process followed by the SNM Value Stream when implementing changes to the organisational structure for the SNM North and South facilities; and
  • SL’s compliance with the licensee’s arrangements for determining, and ensuring compliance with, Minimum Safety Manning Levels (MSMLs) for the SNM North and South facilities.

The inspection comprised discussions with SL staff, review of records, and sampling of information contained within electronic databases and other documentation.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable since this was not a safety system based inspection.

Key Findings, Inspector's Opinions and Reasons for Judgements Made

No significant matters were identified as requiring immediate regulatory attention. I found that SL is largely compliant with its arrangements. I identified one minor area for improvement during the inspection and I consider that it is proportionate to raise a new Regulatory Issue here to be managed as part of normal regulatory business.

My findings were shared with, and accepted by, SL as part of normal inspection feedback.

Conclusion of Intervention

On the basis of the evidence sampled at the time of the inspection, I judge that SL has adequately implemented its arrangements for LC 36 in the SNM Value Stream, with one minor area for improvement identified. Noting the ONR guidance on inspection ratings, it is my opinion that an inspection rating of Green (no formal action) is merited here. A Level 4 (i.e. lowest level) Regulatory Issue has been raised to manage the implementation of the identified area for improvement.