- Site: Sellafield
- IR number: 20-054
- Date: October 2020
- LC numbers: 26
Executive summary
Purpose of Intervention
The Office for Nuclear Regulation (ONR) undertakes all its regulatory interactions with the Sellafield site licensee, Sellafield Limited (SL), against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. In accordance with this strategy, a planned Licence Condition (LC) 26 (Control and supervision of operations) Arrangements Inspection was carried out between 10 August and 12 October 2020.
The main purpose of this inspection was to determine whether the site-wide corporate arrangements made by SL against LC26 adequately meet the requirements of this licence condition.
LC26 requires SL to ensure that no operations are carried out which may affect safety except under the control and supervision of suitably qualified and experienced persons appointed for that purpose by SL.
Since this is an inspection of arrangements, rather than an inspection of the implementation of arrangements at particular operating units on the Sellafield site, an effective inspection can be undertaken which does not involve inspection at the site. Due to the limitations currently in place as a result of the Coronavirus (COVID-19) pandemic it was therefore decided to undertake this inspection remotely via a series of modules undertaken over several weeks.
The inspections comprised discussions with SL staff and reviews of a targeted sample of SL’s documentation. The scope and priorities of the inspection took into account intelligence gained from other ONR interventions.
This inspection was based on SL’s site-wide corporate arrangements to address the requirements of LC26. It did not consider revised Work Delivery arrangements currently being piloted or about to be piloted by SL at selected operating units. It also only considered variations to SL’s site‑wide corporate arrangements related to the COVID‑19 pandemic if SL intends to permanently adopt these moving forwards.
Interventions Carried Out by ONR
The inspections were carried out by an SDFW Inspector, with support from the SDFW Thermal Oxide Reprocessing Plant (THORP) and Oxide Fuel Storage Group (OFSG) Site Inspector and a Chemistry Nuclear Equivalent Inspector. A representative of SL’s Nuclear Intelligence & Independent Oversight (NI&IO) function also participated.
The inspection focussed on the following areas:
- The extent and deployment status of SL’s site-wide corporate arrangements to address the requirements of LC26;
- The experience and training of selected persons assigned responsibility under SL’s site-wide corporate arrangements to address the requirements of LC26;
- The adequacy of records (Licence Condition 6 “Documents, records, authorities and certificates” refers) made to demonstrate compliance with LC26;
- SL’s means of gaining internal assurance of compliance with LC26; and,
- Evidence of the sufficiency of SL personnel to control and supervise all operations on the site which may affect safety.
In carrying out this inspection, the following ONR guidance was used:
- NS-INSP-GD-026 Revision 6, September 2019, “LC26 Control and Supervision of Operations”.
Explanation of Judgement if Safety System Not Judged to be Adequate
Not applicable, as this was not a System Based Inspection.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
I (SDFW Inspector) consider that the engagement prior to and during the inspection has allowed a meaningful inspection of SL’s LC26 arrangements.
On the basis of the evidence sampled before and during this inspection, I identified four good practices:
- Open and honest discussions, including recognition of the need for a LC26 Improvement Plan;
- Recognition of the need to fill relevant vacancies, including for the LC26 Lead;
- Demonstration of good knowledge by all personnel interviewed, including those interviewed who were assigned to control and supervise operations which may affect safety; and,
- Positive responses to ONR’s information requests throughout the inspection.
On the basis of the evidence sampled before and during this inspection, I identified a number of shortfalls which I grouped into the following four themes:
- Relevant operations and roles within the scope of SL’s arrangements;
- Elements of detail in relation to SL’s arrangements for LC26;
- LC26 Compliance Matrix; and,
- LC26 Improvement Plan.
I consider that the shortfalls related to relevant operations and roles are such that SL’s site-wide corporate arrangements do not meet the requirements of LC26 and do not meet ONR relevant good practice expectations as detailed within our guidance. However, I judge that these shortfalls are without prejudice to overall nuclear safety objectives. This is because, as noted earlier, all personnel interviewed assigned to control and supervise operations which may affect safety demonstrated good knowledge. This mitigates the risk gap associated with this theme, although a compliance gap remains. Within this theme the most significant shortfall relates to Operations Control Managers (OCMs) who control and supervise operations which may affect safety being undertaken by tenants on the Sellafield nuclear licensed site. SL understood the basis and significance of this specific shortfall.
I consider that the shortfalls identified relevant to “Detailed matters related to SL’s arrangements”, “LC26 Compliance Matrix” and “LC26 Improvement Plan” are minor when considered individually or as a whole.
In relation to the LC26 Improvement Plan, I will ensure that a plan to address the shortfall related to OCMs is produced first, followed by a plan to address the other shortfalls identified during this inspection.
The NI&IO participant was broadly content with the outcomes of this inspection.
Our findings were shared with, acknowledged and accepted by SL staff involved in the inspection. SL were content with the proposed way forward as a means to ensure a prompt return to compliance with LC26.
Conclusion of Intervention
Taking the above key findings into account I consider that an inspection rating of Amber (Seek Improvement) is merited for SL’s LC26 arrangements, noting the relevant guidance within ONR documentation.
I have raised one Level 3 and three Level 4 (the lowest level) Regulatory Issues to track SL’s progress in addressing the shortfalls identified during this inspection.