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Sellafield - Inspection ID: 22-021

  • Site: Sellafield
  • IR number: 22-021
  • Date: May 2022
  • LC numbers: 7

Executive summary

Purpose of Intervention

The Office for Nuclear Regulation (ONR) undertakes all its regulatory interactions with the Sellafield site licensee, Sellafield Limited, against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. In accordance with this strategy a planned Corporate Licence Condition Intervention (CLCI), targeted at Sellafield Limited’s site‑wide corporate arrangements for compliance with Licence Condition 7 (LC7) “Incidents on the site” and their implementation, was carried out between 17-19 May 2022.

Clause 1 of LC7 states that “The licensee shall make and implement adequate arrangements for the notification, recording, investigation and reporting of such incidents occurring on the site…”. This clause does not explicitly cover wider matters such as operational experience and organisational learning. However, these wider matters are important and the “Chief Nuclear Inspector’s annual report on Great Britain’s nuclear industry. October 2021” notes, in the context of the “Remainder Sellafield Site”, that “Learning” is in “Enhanced attention”. For this reason the scope of this intervention covered:

  • Licence Condition 7 (matters directly related to LC7); and,
  • wider operational experience/ organisational learning.

The objectives of this intervention were to determine the adequacy, judged against ONR’s expectations, of:

  • Sellafield Limited’s operational experience arrangements;
  • Sellafield Limited’s site-wide corporate arrangements made to comply with LC7 and the approved security plan;
  • The interfaces between Sellafield Limited’s site-wide corporate arrangements made to comply with LC7 and particularly relevant other Licence Conditions (LCs);
  • Experience and training of selected persons assigned responsibility under Sellafield Limited’s site-wide corporate arrangements to address the requirements of LC7;
  • Sellafield Limited’s organisational capability related to LC7;
  • Records [Licence Condition 6 (LC6) “Documents, records, authorities and certificates” refers] made to demonstrate compliance with LC7;
  • Sellafield Limited’s means of gaining internal assurance of compliance with LC7; and,
  • Implementation on a sampling basis of Sellafield Limited’s site-wide corporate arrangements to address the requirements of LC7 since 1 April 2017.

This intervention focussed mainly on matters related to ONR’s nuclear safety and nuclear security purposes. Matters related to ONR’s other purposes were covered to a more limited extent.

Interventions Carried Out by ONR

The intervention was carried out by the Sellafield Compliance, Intelligence and Enforcement (SCIE) Corporate Arrangements Inspector with support from: the Sellafield Corporate Inspector; an ONR Regulatory Intelligence Lead; and, a Civil Nuclear Security & Safeguards Inspector.

The intervention comprised discussions with Sellafield Limited staff and reviews of a targeted sample of Sellafield Limited’s documentation. The scope and priorities of the intervention took into account intelligence gained from other ONR interventions. Two remote observations contributed to this intervention.

ONR expectations relevant to the intervention included:

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable, as this was not a System Based Inspection.

Key Findings, Inspector's Opinions and Reasons for Judgements Made

Key findings, Inspector’s opinions and reasons for judgements made are recorded separately in relation to the following areas:

  • the overall intervention;
  • Licence Condition 7; and,
  • wider operational experience/ organisational learning.

The Overall Intervention

I (SCIE Corporate Arrangements Inspector) considered that the engagement prior to and during the intervention allowed ONR to complete a meaningful CLCI of LC7 which included operational experience and organisational learning. I considered that all the objectives of this intervention were met.

I identified the following areas of good practice relating to delivery of this overall intervention:

  • The Sellafield Limited Management System (SLMS) Topic Area 3.09 “Performance Improvement” team delivered the information requested prior to, during and after this intervention promptly. This facilitated development of an evidence base to support this intervention.
  • The Performance Improvement team prepared well for the intervention, which ONR welcomed.
  • Involvement of the Safety Representatives, which ONR welcomed.
  • The Performance Improvement team demonstrated a good internal challenge culture and willingness to learn.
  • All discussions were open, honest and helpful.

Licence Condition 7

On the basis of the evidence sampled before and during this intervention I made a general observation that a comprehensive suite of LC7 arrangements is in place.

On the basis of the evidence sampled before and during this intervention I identified the following areas of good practice relating to Sellafield Limited’s LC7 arrangements and/or their implementation:

  • The organisational change to move the Sellafield Site Sentencing team to be part of the Performance Improvement team.
  • Use of Sellafield Limited’s Licence Condition 36 (LC36) “Organisational Capability” arrangements to manage: the Sellafield Site Sentencing organisational change; and, the recent establishment of a dedicated investigation team as part of the Performance Improvement team, which ONR welcomed.
  • Governance, assurance and oversight of the Analysis, Trending, Learning And Safety (ATLAS) reporting database and the trending tool.
  • Shift co-ordinators rotate around Local Sentencing Meetings to share learning.
  • The “grab packs” documentation form a coherent set which support consistency of reviewing and approving Condition Reports, Local Sentencing etc. across the enterprise.
  • Extensive knowledge and experience of the Board of Inquiry/Management Investigation Lead Investigator and the Basic Cause Investigation Lead Investigator interviewed.
  • The use of the quality guide/ rating sheet for Board of Inquiry/ Management Investigations and Basic Cause Investigations.

On the basis of the evidence sampled before and during this intervention I identified the following items of regulatory advice relating to Sellafield Limited’s LC7 arrangements and/or their implementation. Sellafield Limited to consider:

  • Adding a “Definitions” section to Sellafield Limited Practice (SLP) 3.09.100 “Performance Improvement: Condition Reporting” which defines the meaning of terms such as “incident”, “notification” etc.
  • Following establishment of the Target Operating Model for Performance Improvement, undertaking a gap analysis vs. the current Performance Improvement team capability and establishing a plan to fill any resource gaps.
  • Refreshing the Convening Authority Brief training periodically to persons who undertake this role only infrequently and including this requirement in the updated Technical Competency Framework and Development Guide for Performance Improvement.
  • During the development of the ATLAS replacement, including a requirement to more easily identify Condition Reports originated by contractors / the supply chain.

On the basis of the evidence sampled before and during this intervention, I identified the following regulatory findings relating to Sellafield Limited’s LC7 arrangements and/or their implementation, summarised as follows. Sellafield Limited to:

  • Put in place arrangements to deal with differences of opinion between the Performance Improvement team and Condition Report Owners relating to matters such as sentencing of Condition Reports and the type of investigation to be undertaken.
  • Put in place a proportionate risk based in-the-line assurance programme relating to LC7.

Wider Operational Experience/ Organisational Learning

On the basis of the evidence sampled before and during this intervention I identified the following areas of good practice relating to wider operational experience/ organisational learning:

  • The Performance Improvement team is an active member of the National Operating Experience Learning Group (OELG).
  • The use of business analysis techniques to generate a problem statement on organisational learning weaknesses and the subsequent use of a Board of Inquiry to establish root causes has provided a sound basis for the organisational learning improvement programme.
  • The inclusion of external benchmarking within the organisational learning improvement programme.

On the basis of the evidence sampled before and during this intervention, I identified the following items of regulatory advice relating to wider operational experience/ organisational learning. Sellafield Limited to consider:

  • Emphasising the capture of positive conditions within the Performance Improvement system and dissemination of the learning from such conditions throughout the enterprise.
  • Putting in place arrangements for the systematic capture of external (to Sellafield Limited) operating experience and dissemination of the learning throughout the enterprise.
  • Optimising Key Performance Indicators (KPIs) and action levels used to indicate the health of the Performance Improvement process.

Conclusion of Intervention

The Overall Intervention

The Sellafield Limited personnel present at the hot debrief acknowledged and accepted the intervention outcomes.

Licence Condition 7

On the basis of the evidence sampled I considered that an intervention rating of Green (No Formal Action) for LC7 was merited, having noted the guidance in ONR documentation.

Two Level 4 (the lowest level) Regulatory Issues have been raised to monitor Sellafield Limited’s progress to address the two regulatory findings relating to Sellafield Limited’s LC7 arrangements and/or their implementation identified during this intervention.

Wider Operational Experience/ Organisational Learning

I am satisfied that Sellafield Limited has defined an organisational learning improvement programme which is soundly based and which is capable of producing a sustained improvement in Sellafield Limited’s performance as a learning organisation.

I have provided some advice and guidance to Sellafield Limited relating to its organisational learning improvement programme.

Since the Sellafield Limited’s organisational learning improvement programme pilots are only just underway, no evidence is yet available to demonstrate that anticipated benefits will be realised in practice.

For this reason I consider that it is premature to move Sellafield Limited from “Enhanced attention” relating to learning to “Routine attention”.

To enable a move to “Routine attention” for learning I will recommend that ONR monitors the pilots and the roll out of the organisational learning improvement programme.