- Site: Sellafield
- IR number: 21-065
- Date: August 2021
- LC numbers: 10, 36
Executive summary
Purpose of Intervention
The Office for Nuclear Regulation (ONR) undertakes regulatory interactions with the Sellafield site licensee (Sellafield Ltd, SL) against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. The planned inspection schedule for 2021-22 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 LCs 10 (Training) and 36 (Organisational capability) in the Retrievals value stream. The adequacy of SL's site-wide LC10 and LC36 arrangements is considered separately in other ONR interventions.
Interventions Carried Out by ONR
The inspection of SL’s compliance with LC10 and LC36 in the Retrievals value stream was carried out on 10-11 August 2021. The inspection focussed on the Legacy Ponds and Silos, comprising Pile Fuel Storage Pond (PFSP), First Generation Magnox Storage Pond (FGMSP), Pile Fuel Cladding Silo (PFCS) and Magnox Swarf Storage Silo (MSSS).
LC36(1) requires the licensee to provide and maintain adequate financial and human resources to ensure the safe operation of the licensed site. LC36(2) requires the licensee to make and implement adequate arrangements to control any change to its organisational structure or resources which may affect safety. LC10(1) requires the licensee to make and implement adequate arrangements for suitable training for all those on site who have responsibility for any operations which may affect safety.
The inspection of SL’s compliance with LC36 focussed on the current and future organisational structure and nuclear baseline for Retrievals, and the proposed strategy and arrangements for transition from the current state to the future state. The inspection of SL’s compliance with LC10 focussed on the overall status of training in Retrievals, operation of the training oversight committees, and checks by line managers that staff are Suitably Qualified and Experienced Persons (SQEP) prior to deployment.
The inspection comprised discussions with SL staff, a review of relevant records, and the sampling of information contained within electronic databases and other documentation.
Explanation of Judgement if Safety System Not Judged to be Adequate
This section is not applicable.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
In relation to LC36, SL explained how it manages the nuclear baseline in Retrievals through the use of resource trackers. The trackers clearly identify the status of roles on the baseline and the associated vulnerabilities for each facility within Retrievals. The data shown to ONR indicates that there are significant vulnerabilities in Retrievals (vacancies and others at risk of leaving) amounting to a quarter of the total staff complement. SL was able to demonstrate, however, that it understands and is actively addressing the identified resource gaps on a prioritised basis through workload management, recruitment and other means. Furthermore, the risks associated with these vulnerabilities, and associated mitigating action, have been identified and escalated to the appropriate levels, including the SL Enterprise Performance Committee, a sub-committee of the SL Executive. I was therefore satisfied that SL is adequately addressing the current resource vulnerabilities in Retrievals.
SL has carried out a detailed resource demand analysis for Retrievals over three years. This shows a projected increase in the resources required of around 10% this financial year, however the basis for this projection was not clear. I consider this to be a minor shortfall against ONR’s expectations and have raised a regulatory issue for SL to provide the underpinning justification. Furthermore, SL advised that it will struggle to achieve the projected resource figure and is therefore reviewing the associated risks. As part of the regulatory issue above I have therefore asked SL to report back on how it is managing the risks to future resource demand in Retrievals.
SL has set out a principles paper for the changes it wishes to make to the Retrievals organisation, comprising a merger of the Legacy Silos (PFCS and MSSS) and establishment of a Containment and Storage Operating Unit, which will incorporate the existing and planned new encapsulation plants and associated product stores. The principles paper sets out how the changes will be enacted in stages using SL’s LC36 management of organisational change arrangements. At the time of the inspection SL had decided not to go ahead with the changes until after commencement of retrievals from the Legacy Silos later in 2021-22. SL will review and revise the principles paper at this point. I was satisfied with the approach SL is taking.
In relation to LC10, I identified good practices in relation to line manager visibility of the training status of their teams, format and usability of the training programme descriptions (TPDs) and management oversight of the status of training in Retrievals. However, I also identified a significant shortfall in how training requirements are established and delivered for nuclear safety significant roles in Legacy Ponds. SL has already recognised this shortfall and is in the process of reviewing and revising the TPDs to specify the relevant training for both operations and maintenance roles. In the case of the FGMSP care and surveillance operations, I found that there were inconsistencies between the training requirements stipulated in the current TPD and those contained in individuals’ training profiles. Furthermore, from discussions with team leaders in both PFSP and FGMSP, it was apparent that the training requirements were not fully understood, nor the implications for task deployment should an individual not meet one or more of the training requirements. For the duty shift teams I sampled in Legacy Ponds, I found that a significant proportion of the training requirements (around one-third) were unfulfilled. In the case of both Legacy Ponds and MSSS I also found that a significant proportion of the annual reviews of the SQEP status of individuals by their managers were overdue (respectively 32% and 27%). I have raised regulatory issues for SL to correct the identified shortfalls.
The findings of my inspection (above) were shared with, and acknowledged by, Retrievals management as part of normal inspection feedback.
Conclusion of Intervention
On the basis of the evidence sampled at the time of inspection, I judge that Retrievals has adequately implemented SL’s arrangements for compliance with LC36. In accordance with ONR’s guidance on inspection ratings, I have assigned an inspection rating of ‘Green’ (no formal action). However, I note the future resource vulnerabilities in Retrievals and have therefore raised a Level 4 (lowest level) regulatory issue for SL to explain, firstly, the basis for its resource demand projection and, secondly, the risk of not achieving the required resource level for 2021-22 and the mitigating action being taken.
I judge that Retrievals has not adequately implemented SL’s arrangements for compliance with LC10. I have therefore assigned an inspection rating of ‘Amber’ (formal action required). I have raised a Level 3 regulatory issue for SL to correct the significant shortfalls identified in how it establishes and delivers training requirements for nuclear safety significant roles in Legacy Ponds. I have also raised a Level 4 regulatory issue for both Legacy Ponds and MSSS to address the overdue SQEP periodic reviews by line managers.