- Site: Sellafield
- IR number: 21-038
- Date: June 2021
- LC numbers: N/A
Executive summary
Purpose of Intervention
In 2021-22, the Office for Nuclear Regulation (ONR) is carrying out a Chief Nuclear Inspector’s (CNI) themed inspection on the management of ageing assets. This comprises a series of inspections across nuclear site licensees, the purpose of which is to seek evidence of sustainable programmes for management of ageing assets against four themes: strategy, organisational capability, obsolescence and ongoing investment. Prior to the inspections, each licensee was requested to complete a self-assessment to provide an understanding of the licensee’s arrangements and how they align with the themes for the inspection and supporting criteria. These self-assessments form the basis for the site-based inspections which test the licensee’s compliance with the arrangements and relevant good practice.
Interventions Carried Out by ONR
On 15 June 2021, ONR carried out a themed inspection on management of ageing assets at Sellafield Ltd’s (SL) Special Nuclear Materials (SNM) facilities. The focus of the inspection was on Theme 2 (Organisational Capability), specifically management of organisational capability, succession planning and organisational learning. The inspection comprised discussions with SL staff and review of plant records and other documentation. The inspection was undertaken by specialist inspectors in Leadership and Management for Safety, and Mechanical Engineering, together with the Site Inspector for SNM. The inspection was carried out against Licence Condition 36 (Organisational Capability), specifically LC36(1) which requires (inter alia) the licensee to provide and maintain adequate human resources to ensure the safe operation of the licensed site. The inspection utilised relevant ONR guidance, including NS-INSP-GD-065 (Function and Content of the Nuclear Baseline) and NS-INSP-GD-098 (Asset Management).
Explanation of Judgement if Safety System Not Judged to be Adequate
This was not a system-based inspection, and therefore no judgement has been made of the adequacy of implementation of any part of the safety case.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
During the inspection, I examined SL’s arrangements for management of organisational capability and their implementation in SNM. I was satisfied with SL’s arrangements, which include detailed resource planning over three years, aligned to the overall site operating plan, and an organisational baseline which defines the resource required for safe operation of the SNM facilities, including current vulnerabilities. SNM is also establishing a resource forum to provide a focus for control of resources across its facilities and activities. I found that there were vulnerabilities in SNM’s current organisation including vacancies and other known / potential leavers amounting to around a quarter of the total operational personnel. Subsequent to the inspection, SL were able to provide a satisfactory explanation of how it is managing these vulnerabilities while ensuring safe minimum manning. SL was unable to provide an up-to-date record of an annual review of the adequacy of the organisational baseline, as required by its LC36 compliance arrangements. I have therefore raised regulatory issues for SL to carry out such a review for both SNM Operations and SNM Engineering and Maintenance (E&M).
SL is in the process of implementing two improvements to its sitewide E&M capability: introduction of technical competency framework and a “graded approach” to system engineering. The technical competency framework is expected to improve the management of competence, succession and career development in E&M. The graded approach to system engineering is aimed rebalancing the role of the system engineer towards a more strategic, forward-facing focus on plant reliability rather than a tactical, short term focus on fixing the plant. SNM is on track in implementing this change which will be done in a phased manner. SNM is continuing to participate in the UK Alpha Resilience and Capability programme, which aims to de-risk current alpha work programmes and build national capacity and capability for future missions.
During the inspection I examined SL’s arrangements for succession management, which comprise development and maintenance of succession plans and associated development plans for critical roles, considering both a short term and longer term perspective. SL has a succession plan in place for SNM, however it was unable to provide evidence of associated development plans. This reflects the overall finding from SL’s self-assessment for management of ageing assets, namely that succession planning is not always effective. I have therefore raised a regulatory issue with SL’s corporate HR function to provide assurance of the adequacy its arrangements for succession planning, the current status of compliance across the organisation and the improvement action it is taking as a result.
I examined the implementation of SL’s arrangements for asset condition reporting and follow-up. This includes system health reporting and the role of the plant health committee. I considered the maturity of system health reporting for the most important systems and concluded that this is at an appropriate level of maturity to allow SL’s management to understand where there are shortfalls in terms of asset condition. SL’s plant health committees have an important role within SL’s arrangements for monitoring and recording asset performance and identifying and sentencing corrective actions where these are required. I considered the effectiveness of the SNM committees in fulfilling this role. Based on discussion with the chair and review of meeting records, I concluded that these committees are mature and, are adequately fulfilling the terms of reference including sentencing of recommendations for asset improvement work.
Conclusion of Intervention
I judged from the evidence sampled that SL is effectively managing ageing assets in SNM from the point of view of organisational capability. I have therefore assigned an inspection rating of Green (no formal action) against Licence Condition 36. I found minor shortfalls in the implementation of SL’s arrangements for managing the organisational baseline (periodic review of the adequacy of the baseline) and succession planning, and therefore have raised regulatory issues at Level 4 (lowest level) to track the needed improvements.