- Site: Sellafield
- IR number: 19-100
- Date: September 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 inspection was for ONR to determine the adequacy of implementation of SL’s arrangements for compliance with LC 36 (“Organisational capability”). I focused on sampling evidence of compliance in the Thermal Oxide Reprocessing Plant (THORP) since the provision of adequate human resources is fundamental to the safe operation of these facilities and supports 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 THORP. My inspection focused on:
- SL’s nuclear baseline for THORP (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 THORP when implementing changes to the organisational structure; and
- SL’s compliance with the licensee’s arrangements for determining, and ensuring compliance with, Minimum Safety Manning Levels (MSMLs) for THORP.
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. There is, however, a lack of clarity in how the current nuclear baseline is populated, where gaps exist and how they are being managed. Additionally, SL was unable to provide adequate evidence of a suitable review of the adequacy of the nuclear baseline by the relevant Committees. SL is currently in the process of reviewing the nuclear baseline for THORP in line with preparations for Post Operational Clean Out activities, and I consider that it is proportionate to raise a new Level 4 (i.e. lowest level) Regulatory Issue here to allow ONR to test that SL undertakes a suitable and sufficient review. Follow-up will be managed as part of routine regulatory business.
My findings were shared with, and acknowledged by, THORP’s management 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 THORP has adequately implemented SL’s arrangements for LC 36, 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 areas for improvement.