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Sellafield - Inspection ID: 52091

Executive summary

Date(s) of inspection:

  • March 2023

Aim of inspection

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, this was a planned Corporate Licence Condition Inspection (CLCI) of Licence Condition 36 (LC36) “Organisational capability” targeted at the Sellafield Limited Executive Team. The Sellafield Limited Executive Team was targeted for the following reasons:
  1. To contribute to a wider ONR response to Sellafield being assigned a rating of Enhanced Regulatory Attention for the “Capable Organisation” supporting indicator within ONR’s framework for deciding on the regulatory attention for licensed sites. [Information on regulatory attention is reported in the “Chief Nuclear Inspector’s annual report on Great Britain’s nuclear industry”];
  2. To contribute, in the area of organisational capability, to a wider Sellafield Limited safety leadership intervention by ONR; and,
  3. To follow up an action relating to the “collective competence” of the Sellafield Limited Executive Team placed during a comprehensive CLCI of LC36, which concluded in September 2022.
The objectives of this inspection were to determine, judged against ONR’s expectations, whether or not Sellafield Limited has made and implemented adequate arrangements to:
  1. Determine the competence requirements of individual members of the Sellafield Limited Executive Team related to the five purposes which ONR regulates;
  2. Determine the collective competence requirements of the Sellafield Limited Executive Team related to the five purposes which ONR regulates;
  3. Assess the current competence of individual members of the Sellafield Limited Executive Team against the aforementioned individual competence requirements and manage any gaps;
  4. Assess the current collective competence of the Sellafield Limited Executive Team against the aforementioned collective competence requirements and manage any gaps; and,
  5. Manage changes (both planned and reactive) to the Sellafield Limited Executive Team to maintain the required individual and collective competence.
An additional objective was to consider the role of the Sellafield Limited Board Nominations Committee in relation to objectives a.-e.

Subject(s) of inspection

  • LC 36 - Organisational capability - Rating: Green

Key findings, inspector's opinions and reasons for judgement made

This CLCI of LC36 targeted at the Sellafield Limited Executive team was led by the Sellafield Compliance, Intelligence and Enforcement (SCIE) Corporate Arrangements Inspector with support from: a Civil Nuclear Security and Safeguards (CNSS) Inspector; a Leadership and Management for Safety (LMfS) Inspector; and, a Conventional Health and Safety (CHS) Inspector. Henceforth, the use of the pronoun “we” refers to this inspection team whilst the pronoun “I” refers to the SCIE Corporate Arrangements Inspector. The inspection involved discussions with Sellafield Limited staff, including four members of the Sellafield Limited Executive team, and reviews of a targeted sample of Sellafield Limited’s documentation. The scope and priorities of the inspection took into account intelligence gained from other ONR inspections at the Sellafield site, and in particular a comprehensive CLCI of LC36 which concluded in September 2022 (WIReD Record IIS-50319). This inspection included several interviews at site on 1 March 2023 (including one with a member of the Sellafield Limited Executive Team) supported by interviews undertaken remotely on 13 and 14 February 2023 with three other members of the Sellafield Limited Executive Team. We considered that the engagement prior to and during the inspection allowed us to complete a meaningful CLCI of LC36 targeted at the Sellafield Limited Executive Team. We considered that all the objectives of this inspection were met. We identified the following observations as areas of good practice relating to delivery of the overall inspection:
  1. Prompt delivery of the information requested prior to and during the inspection;
  2. Preparation for the inspection; and,
  3. Open, honest and helpful discussions and the enthusiasm and knowledge of those involved.
On the basis of the evidence sampled before and during this inspection we identified the following observations as areas of good practice relating to arrangements and their implementation:
  1. The Executive Director induction material and the use of this by all members of the Executive Team;
  2. During Executive Team succession planning, a look is made across the Nuclear Decommissioning Authority (NDA) and Sellafield Programme and Project Partners (PPP), thereby opening up the pool; and,
  3. Behaviours outlined in “The NDA group Leadership Standard” and the “Sellafield Limited Nuclear Professionalism Standards and Expectations” are broadly aligned to ONR’s “Safety Leadership” Technical Assessment Guide (TAG) and all members of the Sellafield Limited Executive Team have been evaluated against the “The NDA group Leadership Standard”.
On the basis of the evidence sampled before and during this inspection we identified the following observations as advice. Sellafield Limited to consider:
  1. How it could better capture any competence gaps and associated actions related to individuals identified as they worked through the Executive Director induction material and any improvements to the Executive Director induction material itself in an enduring way; and,
  2. How the gap in cyber security competence acknowledged by the Sellafield Limited Nominations Committee can best be addressed.
On the basis of the evidence sampled before and during this inspection, we identified no regulatory findings, representing gaps against relevant good practice. Based on this I considered that an Inspection Rating of Green (No Formal Action) for LC36 was appropriate, noting the relevant guidance within ONR documentation. The Sellafield Limited personnel present at the hot debrief were in broad agreement with the outcomes of this inspection.

Conclusion

On the basis of the evidence sampled before and during this inspection, we identified no regulatory findings representing gaps against relevant good practice. Based on this I considered that an Inspection Rating of Green (No Formal Action) for LC36 was appropriate, noting the relevant guidance within ONR documentation.