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Sellafield Site - Inspection ID: 50319

Executive summary

Date(s) of inspection:

  • August 2022

Aim of inspection

Each year the Office for Nuclear Regulation (ONR) performs a series of planned Corporate Licence Condition Inspections (CLCIs) in accordance with the “ONR Sellafield Strategy 2020 - 2025” and the supporting “ONR Sellafield Compliance, Intelligence and Enforcement (SCIE) Sub-Division Plan 2020 - 2025”. The principal purpose of these inspections is to seek assurance that: Sellafield Limited’s site-wide/ corporate written arrangements are adequate to ensure the Sellafield site’s compliance with the conditions of its nuclear site licence; and, the arrangements are being adequately implemented at the site-wide/ corporate level. This inspection was a planned CLCI of Licence Condition 36 (LC36) “Organisational capability”. Due to the wide scope of the topics covered in this CLCI the inspection consisted of two modules. Module 1 was an early LC36 information gathering engagement undertaken on 12 April 2022 whilst Module 2 was an inspection undertaken between 31 August and 2 September 2022. An additional supplementary purpose of this inspection was to provide evidence to inform, for the overall Sellafield Enterprise, the rating 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”.

Subject(s) of inspection

  • LC36 - Organisational capability - Rating: Green

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

This CLCI of LC36 was led by the SCIE Corporate Arrangements Inspector with support from: a Civil Nuclear Security (CNSS) inspector; and, the Sellafield Corporate Inspector. A secondee from the Nuclear Regulation Authority in Japan observed the inspection and a member of Sellafield Limited’s Nuclear Independent Oversight (NIO) function participated in the inspection. 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 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 and the early LC36 information gathering engagement on 12 April 2022, which was followed-up as required during this inspection. Taking into account the principal and supplementary purposes of this inspection, key findings and judgements made are recorded separately in relation to the following areas:
  1. The overall inspection;
  2. Licence Condition 36; and,
  3. Capable Organisation regulatory attention indicator.

The Overall Inspection

We considered that the engagement prior to and during the inspection allowed us to complete a meaningful CLCI of LC36 and support a recommendation relating to the Capable Organisation regulatory attention indicator. 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;
  3. Open, honest and helpful discussions and the enthusiasm and knowledge of those involved; and,
  4. The positive response to the observations and advice provided.

Licence Condition 36

On the basis of the evidence sampled before and during this inspection we identified the following observations as areas of good practice relating to Sellafield Limited’s LC36 arrangements and/ or their implementation:
  1. Induction arrangements and their implementation for external recruits to the Sellafield Limited Executive and Senior Management;
  2. Improved arrangements for managing the collective competence of the Sellafield Limited Executive and Senior Management;
  3. Arrangements to ensure that “emergency successors” are in place for all members of the Sellafield Limited Executive and Senior Management;
  4. Systematic implementation of Sellafield Limited’s LC36 arrangements to changes to the Sellafield Limited Executive and Senior Management; and,
  5. Development of a suite of trackers which serve as a useful aide to Duty Holders in managing the nuclear baseline.
On the basis of the evidence sampled before and during this inspection we provided the following regulatory advice relating to Sellafield Limited’s LC36 arrangements and/ or their implementation. Sellafield Limited to consider:
  1. Including within its LC36 arrangements a statement to the effect that changes to the security organisation as defined in the nuclear site security plan require ONR’s prior Approval;
  2. Signposting in its LC36 arrangements the justification of there being adequate emergency response capability to deal with foreseeable multi-facility site emergencies;
  3. How the Sellafield site Management of Change Committee (SL MoCC) could better capture its reviews of: the adequacy of the Enterprise nuclear baseline; the cumulative impact of change; and, the Enterprise’s capacity for change;
  4. Revising relevant written arrangements to explicitly provide ONR with LC36 derived powers, which should then be signposted in the LC36 Compliance Matrix; and,
  5. Improving the interfaces between the documented nuclear baseline and the strategy and planning and human resources work leading to the Capability Plans.
On the basis of the evidence sampled before and during this inspection, we identified the following regulatory findings relating to Sellafield Limited’s LC36 arrangements and/ or their implementation. Sellafield Limited to:
  1. Reference relevant existing SLMS documents in the LC36 Compliance Matrix, so that relevant strategy and planning and human resource activities form part of Sellafield Limited’s LC36(1) arrangements; and,
  2. Review arrangements referenced in the LC36 Compliance Matrix to ensure that a full set of records required to demonstrate compliance with LC36 is being made.

Capable Organisation Regulatory Attention Indicator

During the CLCI of LC36 we obtained evidence that Sellafield Limited is managing its Enterprise nuclear baseline and the known gaps and vulnerabilities. Nonetheless we obtained evidence during the CLCI of LC36 to support the following:
  1. There are currently a number of approved vacancies in the Enterprise nuclear baseline where recruitment is proving difficult and the forward outlook in terms of factors such as demographics looks challenging;
  2. Mitigated breaches of minimum safety manning levels occur on a regular basis;
  3. Programmes are sometimes not being progressed due to resource challenges;
  4. The LC35 Owner assigned an Amber rating for LC36 in a paper to the Sellafield Limited Nuclear Safety Committee (SLNSC); and,
  5. NIO has confirmed the position reflected above in a separate paper to the SLNSC.
In ONR’s framework for deciding on the regulatory attention for licensed sites, the “Capable Organisation” supporting indicator is under the “Safety Leadership and Culture” attribute of nuclear safety performance. Supporting indicators under this attribute are mainly leading indicators in the sense that they provide an early warning of declining performance rather than reflect actual performance (as often represented by lagging indicators). Lagging indicators are mainly under the “Safety Performance” and the “Control of Hazards and Risks” attribute of nuclear safety performance in ONR’s framework for deciding on the regulatory attention for licensed sites. On the basis of the evidence sampled and the need to act to avert future declining safety performance I have recommended, in relation to the Sellafield remainder of estate regulatory attention levels, that Organisational Capability is moved from Routine Regulatory Attention to Enhanced Regulatory Attention.

Conclusion

Taking into account the principal and supplementary purpose of this inspection, judgements made are recorded separately in relation to the following areas:
  1. The overall inspection;
  2. Licence Condition 36; and,
  3. Capable Organisation regulatory attention indicator.

The Overall Inspection

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

Licence Condition 36

On the basis of the evidence sampled I considered that an inspection rating of Green (No Formal Action) for LC36 was merited, having noted the guidance in ONR documentation. One Level 4 (the lowest level) Regulatory Issue has been raised to monitor Sellafield Limited’s progress to address the two regulatory findings relating to Sellafield Limited’s LC36 arrangements and/or their implementation identified during this inspection.

Capable Organisation Regulatory Attention Indicator

On the basis of the evidence sampled and the need to act to avert future declining safety performance I have recommended, in relation to the Sellafield remainder of estate regulatory attention levels, that Organisational Capability is moved from Routine Regulatory Attention to Enhanced Regulatory Attention.