- Site: Sellafield
- IR number: 21-057
- Date: July 2021
- LC numbers: 17
Executive summary
Purpose of Intervention
The Office for Nuclear Regulation (ONR) undertakes regulatory interaction with the Sellafield site licensee (Sellafield Limited (SL)) against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. Following a number of recent supply chain events, ONR conducted a targeted supply chain intervention at Sellafield. The intention is to conduct a series of supply chain intervention across the Sellafield Ltd site to inform a regulatory judgement regarding the licensee’s compliance with relevant statutory provisions and good practice. The purpose of this intervention was to sample evidence of implementation of Sellafield Ltd’s Supply Chain Management arrangements within the Magnox Swarf Storage Silo.
Interventions Carried Out by ONR
The Nominated Project Inspector and a Nuclear Safety Supply Chain Inspector carried out the intervention. The intervention included a review of relevant documentation supplied by Sellafield Ltd in advance of, and during, the inspection. The inspection focused on:
- Development and issue of Specifications - Licensee’s arrangements for development of specifications which adequately describe the items or services and reflect the design intent, design codes & standards to meet safety case requirements. Including determination and application of proportionate quality assurance and inspection arrangements, the cascade of requirements through the supply chain; and
- Contract delivery - Licensee’s arrangements for delivering the contract, use of sub-contractors, management of records, deviation from specification, oversight and assurance (including Intelligent Customer and Design Authority), and cascading and understanding the expectations for a supplier of high-risk items to the nuclear industry. Including capability to oversee and assess supply chain performance and to provide a level of oversight and assurance commensurate with the risk of the item failing to meet specified intent, such as third-party assurance and verification of items or services, acceptance of goods and mitigation of Counterfeit, Fraudulent and Suspect Items (CFSI) risks.
The purpose of this inspection was to sample implementation of the Supply Chain Management arrangements within the Retrievals Value stream, targeting a number of the Magnox Swarf Storage Silo (MSSS) high hazard and risk reduction projects. This intervention will inform our regulatory judgement regarding the licensee’s compliance with relevant statutory provisions and good practice.
The intervention was undertaken against LC17(2) and informed by ONR’s technical assessment guides NS-TAST-GD-077: Supply Chain Management Arrangements for the Procurement of Nuclear Safety Related Items or Services, Revision 5 (July 2019), NS‑TAST‑GD‑049: Licensee Core and Intelligent Customer Capabilities, Revision 7 (April 2019), and NS-TAST-GD-079: Licensee Design Authority Capability, Revision 6 (June 2020) informed the inspection.
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
The following summarises the key observations arising from discussions, sampled documentation and inspection of the Supply Chain arrangements during the intervention.
I examined a sample of the procurement and project documentation relating to the design, fabrication and installation of Nitrogen supply pipework. A shortfall was identified in Sellafield Ltd’s Quality plan for compartments 1-12 (excluding 10). This shortfall represents a departure from Sellafield Ltd’s extant corporate arrangements for compliance with LC17. The shortfall related to inadequate Quality Plan discipline consisting of missed “hold points” and the use of “post-it notes” (sticky notes) for capturing signatures in lieu of signing the document itself. Therefore, a Level 3 Regulatory Issue (seek improvement) has been raised to track Sellafield Ltd action to address the compliance gap.
I also identified a minor shortfall, in the approach to approval of subcontractors and the follow-up of supplier audits, as Sellafield Ltd were unable to provide evidence of the correct closure of a supplier audit within the inspection time frame this will be followed up as a Level 4 (i.e. lowest level) issue as part of routine regulatory business.
I also sampled the procurement of a nitrogen flow meter safety mechanism and found evidence sufficient to provide confidence that compliance with Sellafield Ltd’s corporate arrangements for the procurement, availability of spares and inclusion on the Plant Maintenance Schedule was being adhered to.
I noted three particular areas of good practice, these were in relation to the approach to the identification of intelligent customer role holders within the project documentation, the early contractor involvement in the form of the constructability report and the response taken to a recent Retrievals value stream mechanical test record falsification event.
My findings were shared with, acknowledged and accepted by MSSS Commercial Manager and Senior Project Manager as part of normal inspection feedback.
Conclusion of Intervention
Based on the evidence sampled at the time of the inspection, and cognisant of the shortfall relating to Quality Planning, I judge that Magnox Swarf Storage Silo has failed to adequately meet Sellafield Ltd’s compliance arrangements for LC 17 and Relevant Good Practice. Noting the ONR guidance on inspection ratings, it is my opinion that an inspection rating of Amber (seek improvement) is merited here. The ONR Enforcement Management Model (EMM) will be applied to determine an appropriate regulatory response and, further to this, a level 3 regulatory issue has been raised.