- Site: Sellafield
- IR number: 21-134
- Date: December 2021
- LC numbers: 17
Executive summary
Purpose of Intervention
The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Sellafield site licensee (Sellafield Limited) against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division.
The purpose of this intervention was to sample evidence of implementation of Sellafield Ltd’s Supply Chain Management arrangements (LC 17, Management systems) for the procurement of Self-Shielded Boxes (SSBs) to inform a regulatory judgement regarding the licensee’s compliance with relevant statutory provisions and good practice. The findings from this inspection will be used to inform the decision in response to Sellafield Limited’s request for ONR agreement to commence retrievals of legacy material from First Generation Magnox Storage Pond (FGMSP) into SSBs for storage in an Interim Storage Facility.
Interventions Carried Out by ONR
The inspection was undertaken on the 01 and 02 December 2021 by a team comprising of the Supply Chain specialist Nuclear Safety Inspector supported by the Project Inspector, a Mechanical Engineering specialist inspector, and a Structural Integrity specialist inspector.
LC 17 (Management systems) requires Sellafield Limited to make and implement management systems which give due priority to safety. LC 17 also requires Sellafield Limited to make and implement adequate quality management arrangements in respect of all matters which may affect safety.
The inspection sampled the application of Sellafield Ltd’s documented Supply Chain Management Arrangements within the Retrievals Value stream, targeting the Self-Shielded Box procurement. The first part of the intervention was undertaken remotely (23 September 2021), this intervention record captures the second part of the intervention focusing on Goodwin Steel Castings and Goodwin International.
The inspection comprised a review of relevant documentation supplied by Sellafield Ltd in advance of, and during, the inspection plus group discussions with members of the Sellafield Ltd project team and suppliers Westinghouse Electric Company UK (Main Contractor), Goodwin Steel Castings (Casting subcontractor) and Goodwin International (Machining subcontractor) and a facility walkdown of the Goodwin manufacturing facilities (Foundry and Machine Shop).
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
No significant matters were identified as requiring immediate regulatory attention in relation to the implementation of the LC 17 arrangements for the procurement of SSBs from Westinghouse and its subcontractors.
I found that Sellafield Ltd demonstrated an adequate understanding of Sellafield Ltd’s site-wide arrangements for LC 17 and has adequately implemented these arrangements, including the implementation of quality management arrangements proportionate to the safety risk. In line with Sellafield arrangements and relevant good practice the SSBs have been assigned Quality Grade 2, and the requirements have been cascaded to the supplier via a contract. Sellafield Ltd are currently considering the appropriate level of oversight and assurance as they gain confidence in the Supply Chain to meet safety case requirements and the SSBs move into volume manufacture.
Whilst the intervention provided me with some assurance that the supply chain is capable of meeting the safety case requirements, the next stage of the procurement will require an increase in throughput. There are challenges associated with the increase in manufacturing capacity from the current throughput (five SSBs/month) to the desired throughput (ten SSBs/month). Whilst it was apparent work is underway to address these challenges (both technical and commercial), Sellafield Ltd will need to work with the supply chain to agree solutions and jointly overcome these challenges. I advised Sellafield Ltd that it will be required to demonstrate an adequate supply of SSBs to support hazard and risk reduction and ultimately decommissioning commitments made under LC 35 (Decommissioning). Whilst capacity did not factor into the rating of the intervention, intelligence gained from this intervention will be used to inform a number of strategic discussions at Delivery Lead level.
I identified one minor shortfall, in relation to the specialist casting expertise competency gap, both in the SSB project team and the wider organisation. This will be followed up as a Level 4 (i.e. lowest level) issue as part of routine regulatory business.
A number of further areas were identified for follow up as part of future routine regulatory interactions. These include: the cascade of nuclear safety culture and Counterfeit, Fraudulent and Suspect Items (CFSI) training and awareness briefs to shopfloor operators and the potential change to inhouse testing laboratories.
My findings were shared with, acknowledged and accepted by Sellafield Limited and supplier staff involved in the inspection.
Conclusion of Intervention
On the basis of the evidence sampled at the time of the inspection, I judge that Retrievals has adequately implemented Sellafield Ltd’s arrangements for LC 17, with one minor shortfall identified. Noting the ONR guidance on inspection ratings, it is my opinion that an inspection rating of Green (no formal action) is merited. One Level 4 regulatory issue has been raised to manage the resolution of the identified minor shortfall.