Executive summary
Date(s) of inspection:
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 28 (LC28) “Examination, inspection, maintenance and testing” targeted at System Engineering (SE) resources. In the remainder of this Inspection Record (IR), SE is used as an umbrella term covering two roles:
a. Plant Engineering; and,
b. Reliability Engineering.
SE resources were targeted for the following reasons:
a. In relation to ONR’s framework for assigning regulatory attention for safety purposes (see, ONR-GEN-GD-013, “Guidance on the Assignment of Dutyholder Attention Levels”), the whole of Sellafield is in Enhanced Regulatory Attention for “Capable Organisation”;
b. Shortfalls in SE resources is a recognised issue at Sellafield which was considered during a CLCI of Licence Condition 36 (LC36) “Organisational capability” in August-September 2022 (Inspection Record IIS-50319) and during a CLCI of LC28 in September 2022 (Inspection Record IIS-50317). The CLCI of LC28 led to Level 4 (the lowest level) Regulatory Issue (RI)-11359 “Sellafield - LC28 Inspection - System Engineering Resources (Site-Wide)” being raised; and,
c. The “Chief Nuclear Inspector’s themed inspection on the management of ageing facilities. 2022” identified a thematic common challenge “Ensuring sustainable capability and skills necessary for the management of ageing”.
Subsequent to the planning of this inspection, a LC28 inspection (IR-52421) at the High Level Waste Plants (HLWP) facility and at the Highly Active Liquor Evaporation and Storage (HALES) facility rated LC28 Amber and led to Level 3 RI-11456 “HALES and HLWP LC28 shortfalls - Asset Management and Maintenance Backlogs” being raised. A root cause of these backlogs is a resource shortfall in engineers.
Subject(s) of inspection
- LC28 - Examination, inspection, maintenance and testing - Rating: Amber
Key findings, inspector's opinions and reasons for judgement made
We (Sellafield Corporate Arrangements Inspector and Mechanical Engineering Inspector) undertook a targeted Corporate Licence Condition Inspection (CLCI) of Licence Condition 28 (LC28) “Examination, inspection, maintenance and testing”, specifically targeted at System Engineering (SE) resources.
Historic inspection activities in August and September 2022 highlighted shortfalls against SE resources, resulting in Level 4 (the lowest level) Regulatory Issue (RI)-11359 being raised. These shortfalls were also related to the “Chief Nuclear Inspector’s themed inspection on the management of ageing facilities. 2022” common challenge area - “Ensuring sustainable capability and skills necessary for the management of ageing”.
The aim of this inspection was to establish, judged against ONR’s expectations, whether or not Sellafield Limited has:
a. Established and justified a “SE Baseline”, which is the total System Engineering staffing levels and competence required to implement and maintain its Asset Management System (AMS) arrangements;
b. A realistic forward look in place of likely internal challenges (for example, demographics) and external challenges (for example, competition from other employers) to the SE Baseline over the next three years;
c. Developed a strategy and plan for filling gaps in the SE Baseline which takes into account likely internal and external challenges over the next three years;
d. Put in place a well-founded set of performance indicators to monitor the health of the SE Baseline; and,
e. Accumulated evidence to demonstrate that the strategy and plan for filling gaps in the SE Baseline is delivering the anticipated outcomes.
We undertook a desktop review of documentation prior to the inspection, and this was followed by a face to face inspection with members of the Sellafield Limited Engineering and Maintenance team.
We consider that the engagement prior to and during this inspection has allowed a meaningful CLCI of LC28 targeted at SE resources to be completed which met the objectives described above.
We consider that Engineering and Maintenance understands plant needs and has implemented the relevant Sellafield Limited Practices to generate a realistic estimate of the site-wide SE resources required now and going forwards. We consider that all individuals spoken to were clearly invested in making improvements and are doing all they can, within the current constraints, to secure and maintain adequate SE resources.
However, the inspection found that there is still a gap between the site-wide SE resources required and the resources currently in place, and that closure of this gap in the near term is not a realistic possibility. This is resulting in a site-wide shortfall in required system health reviews and reporting so that risks that may challenge the capability of assets to support or deliver a safety function are not being effectively managed through-life across the site.
Although Sellafield Limited recognises the shortfalls in SE resources, and is making attempts to close these shortfalls, it was not able to demonstrate that the risks associated with the ongoing shortfalls in SE resources are being effectively managed. For example, Sellafield Limited was not able to demonstrate that the allocation of the available SE resources was targeted at the most safety significant assets and that contingency measures were available where SE resources are needed but not currently allocated.
I (Sellafield Corporate Arrangements Inspector) consider that the current situation caused by the lack of site-wide SE resources has led to a systematic failure by Sellafield Limited to implement its Licence Condition 28 compliance arrangements in the area of System Engineering.
In addition to shortfalls against LC28, I consider that the current situation also represents a shortfall against several other Licence Conditions, including Licence Condition 36 (LC36) “Organisational capability” and Licence Condition 15 (LC15) “Periodic review”.
Overall, I do not consider that Sellafield Limited has adequate SE resources in place to be able to recognise and assess longer term impacts on Structures, Systems and Components (SSCs), taking due consideration of asset management requirements (for example, ageing and degradation and obsolescence).
I have assigned a rating of amber - Seek improvement, to this inspection.
I will apply ONR’s Enforcement Management Model (EMM) to this situation and propose a Level 3 RI “Sellafield - Managing the Risks Associated with Shortfalls in System Engineering Resources (Site-Wide)” to monitor Sellafield Limited’s work to address the shortfalls identified in this inspection.
Conclusion
I (Sellafield Corporate Arrangements Inspector) consider that Engineering and Maintenance understands plant needs and has implemented the relevant SLPs to generate a realistic estimate of the site-wide SE resources required now and going forwards. It was also evident that all individuals spoken to are clearly invested in making improvements and are doing all they can, within the current constraints, to secure and maintain adequate SE resources.
However, the inspection found that there is still a gap between the site-wide SE resources required and the resources currently in place, and that closure of this gap in the near term is not a realistic possibility. This is resulting in a site-wide shortfall in required system health reviews and reporting so that risks that may challenge the capability of assets to support or deliver a safety function are not being effectively managed through-life across the site.
Although Sellafield Limited recognises the shortfalls in SE resources, and is making attempts to close these shortfalls, it was not able to demonstrate that the risks associated with the ongoing shortfalls in SE resources are being effectively managed. For example, Sellafield Limited was not able to demonstrate that the allocation of the available SE resources was targeted at the most safety significant assets and that contingency measures were available where no SE resources are currently allocated.
I consider that the current situation caused by the lack of site-wide SE resources has led to a systematic failure by Sellafield Limited to implement its Licence Condition 28 compliance arrangements in the area of System Engineering.
In addition to shortfalls against LC28, I consider that the current situation also represents a shortfall against several other Licence Conditions, including LC36 and LC15.
Overall, I do not consider that Sellafield Limited has adequate SE resources in place to be able to recognise and assess longer term impacts on SSCs, taking due consideration of asset management requirements (for example, ageing and degradation and obsolescence).
I have assigned a rating of amber - Seek improvement, to this inspection and so I will apply ONR’s Enforcement Management Model (EMM).
I will propose a Level 3 RI “Sellafield - Managing the Risks Associated with Shortfalls in System Engineering Resources (Site-Wide)” to monitor Sellafield Limited’s work to address the shortfalls identified in this inspection.