Executive summary
Date(s) of inspection
- October 2023
Aim of inspection
In accordance with the Office for Nuclear Regulation’s (ONR’s) Sellafield Strategy, each year ONR performs a series of planned compliance inspections of selected licence conditions, targeted at those facilities with significant importance to nuclear safety. One such inspection was undertaken to assess FGMSP’s compliance with Sellafield Limited’s corporate arrangements for Licence Condition 12 (Duly authorised and other suitably qualified and experience persons), Licence Condition 26 (Control and Supervision of Operations) and Licence Condition 36 (Management of Change) on 3rd and 4th October 2023.
The inspection was undertaken by Vicki Keene, Martin Reid and Val Alderson. NIO also attended.
Subject(s) of inspection
- LC12 – Duly authorised and other suitably qualified and experienced persons – Rating: Green
- LC26 – Control and supervision of operations – Rating: Green
- LC36 – Organisational capability – Rating: Amber
Key findings, inspector’s opinions and reasons for judgement made
In accordance with the Office for Nuclear Regulation’s (ONR’s) Sellafield Strategy, each year ONR performs a series of planned compliance inspections of selected licence conditions, targeted at those facilities with significant importance to nuclear safety.
On the 3rd and 4th October 2023, ONR carried out a planned two day inspection of FGSMP (First Generation Magnox Storage Ponds) utilising two Human Factors Inspectors. The inspection focused on assessing FGMSP’s compliance with Sellafield Limited’s corporate arrangements for Licence Condition 12 (Duly authorised and other suitably qualified and experience persons), Licence Condition 26 (Control and Supervision of Operations) and Licence Condition 36 (Organisational Capability).
ONR examined evidence to verify the adequacy of the implementation of Sellafield Limited’s arrangements for three Licence Conditions (LCs). This was achieved through a combination of document reviews, presentations by the licensee, plant visit and discussions with operators and maintenance staff.
The ONR Inspection Team consider that Sellafield Ltd has demonstrated compliance with LC12 and LC26 in FGMSP and therefore assign a green rating for LC12 and LC26. There is no further regulatory action required and no regulatory issues raised for LC12. However in relation to LC26, a potential disconnect was identified between the OPMs (Limits and Conditions of the Safety Case) listed in the Clearance Certificates and who should ensure compliance with each OPM. While there were no immediate safety concerns, this has been identified as a shortfall to expectations. The identified shortfall will be managed by Level 4 Regulatory Issue (RI) 11757.
Based on the lack of clear operating plan within FGMSP at the time of the inspection and the routine failure to meet Minimum Safety Manning Levels (MSMLs), LC 36 was rated Amber. However, the ONR Inspection team recognise that work is currently being undertaken by FGMSP to develop their Target Operating Plan (and associated Resource Plan) and that work is currently being undertaken by Sellafield Limited to address the capability issue. These activities are being overseen via a FGMSP specific RI (RI 11513) and the ONR Corporate team respectively. It is therefore not considered appropriate for a further RI to be raised in relation to LC36.
Conclusion
Overall, the ONR inspection team found LCs 12 and 26 to be adequately implemented in FGMSP. Consequently, a rating of green – No formal action is appropriate for these LCs. However, a L4 regulatory issue will be raised due to the potential disconnect between the OPMs (Limits and Conditions of the Safety Case) listed in the Clearance Certificates and who should ensure compliance with each OPM.
An inspection rating of amber – Seek improvement is appropriate against LC36 because of the lack of a clear plan within FGMSP at the time of the inspection and the routine failure to meet MSMLs. However, recognising that there is ongoing regulatory oversight in this area current, no further action will be taken.