- Site: Sellafield
- IR number: 21-107
- Date: October 2021
- LC numbers: 17
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 the 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 18 October 2021, ONR carried out a themed inspection on the management of ageing assets by Sellafield Ltd’s corporate Engineering and Maintenance team. The focus of the inspection was on Theme 4 (sustained focus and commitment to ongoing investment in plant, people and processes concerned with ageing management), specifically, Sellafield Ltd’s management arrangements. The inspection comprised discussions with Sellafield Ltd staff, a review of management arrangements and other documentation. The inspection was undertaken by specialist inspectors in Leadership and Management for Safety, Civil Nuclear Security, Safeguards and Mechanical Engineering, together with ONR’s Executive Director of Operations. The inspection was carried out against Licence Condition 17 (management systems). The inspection utilised relevant ONR guidance, including NS-INSP-GD-017 (LC17 – Management systems) and NS-INSP-GD-098 (Asset Management).
This Intervention Record includes the findings from the ONR Nuclear Safety, Civil Nuclear Security and Safeguards inspectors.
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
I examined Sellafield Ltd’s arrangements for investment in people, plant and processes related to ageing management. I found shortfalls in the number of people within Sellafield Ltd’s engineering and maintenance organisation. The licensee outlined its plan to address these shortfalls through recruitment and through seeking more efficient ways of working within engineering and maintenance.
I examined Sellafield Ltd’s arrangements for assuring the effective implementation of its arrangements for management of ageing assets. These comprise a variety of means including annual assessments of the maturity of each operating unit’s equipment reliability arrangements, Tier 1 or ‘in line’ assurance (although this is not mandated), Tier 2 process owner assurance (current focus on effectiveness of plant health committees, although ‘deep dive’ reviews have been suspended for the past 18 months) and Tier 3 independent assurance by external parties such as LRQA and WANO. This assurance is demonstrating that Sellafield Ltd has made progress on implementation of its ageing management arrangements although not yet achieved that level of maturity that it expects to ensure pro-active, risk-informed, asset decision-making. I found a lack of clarity in the targets Sellafield Ltd has set for improvements in the maturity of equipment reliability arrangements and insufficient ‘deep dive’ reviews (or equivalent) by the process owner, which I consider to be a significant element of assurance given the flexibility SL has allowed in application of its equipment reliability processes by operating units.
I considered Sellafield Ltd’s use of operational experience and lessons learned from the nuclear industry and other industries. Sellafield Ltd provided two examples where this has been applied to the management of ageing assets. I was satisfied with the examples provided by Sellafield Ltd on this topic.
Conclusion of Intervention
I was satisfied overall that Sellafield Ltd has adequately implemented its arrangements for compliance with Licence Condition 17 (Management systems) and therefore consider an inspection rating of ‘Green’ (no formal action) to be appropriate. I found minor shortfalls in Sellafield Ltd’s arrangements for assurance of the effective implementation of its arrangements for ageing management, namely the clarity of targets for improvement of the maturity of its equipment reliability arrangements and implementation of process owner (‘Tier 2’) assurance. I have therefore raised a regulatory issue at Level 4 for Sellafield Ltd to address these shortfalls.