Executive summary
Date(s) of inspection
- October 2023
Aim of inspection
The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Sellafield site licensee (Sellafield Ltd (SL)) against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. In accordance with this strategy, an inspection on the adequacy of Sellafield Ltd’s Supply chain management (SCM) arrangements for the Infrastructure Strategic Alliance (ISA) is scheduled. The purpose of this inspection is to sample evidence on the adequacy and implementation of SCM arrangements for the ISA in order to inform a regulatory judgement regarding the licensee’s compliance with relevant good practice.
The inspection will be undertaken against Licence Condition (LC) 17 ‘Management systems’ and LC 26 ‘Control and supervision of operations’.
Subject(s) of inspection
- CDM 15 (Client / PD / PC duties) – Rating: Not rated
- COMAH – Control of Major Accident Hazards Regulations 2015 – Rating: Not rated
- Control of Contractors – Rating: Not rated
- Health & Safety at Work Act – Rating: Not rated
- LC 17 – Management systems – Rating: Amber
- LC 26 – Control and supervision of operations – Rating: Green
- MHSWR – Rating: Not rated
Key findings, inspector’s opinions and reasons for judgement made
The focus of the inspection was to seek assurance that the Infrastructure Strategic Alliance (ISA) has implemented adequate supply chain management arrangements, including lifetime records for the delivery of the Electrical Distribution Network Upgrade (EDNU) Project on the Sellafield site.
Based on the discussions held and evidence sampled during the inspection, I concluded that the ISA has delivered improvements for the oversight of site-based installation and manufacturing activities. However, it is acknowledged that further developments are required to deliver increased effectiveness of the oversight and verification arrangements, including the timely delivery of lifetime records.
The ISA provided an overview of its quality management and supply chain management arrangements for the delivery of EDNU Project. I noted there has been improvements in the control, reporting structure and approach to improve supply chain quality performance, but I considered there was limited evidence to adequately demonstrate the consistent implementation of the required project quality management arrangements.
Based on the evidence sampled, there are required improvements to demonstrate the adequate deployment of the Intelligent Customer assurance arrangements.
I identified significant shortfalls in the adequate deployment of the quality management arrangements to mitigate the risks of Counterfeit, Fraudulent and Suspect Items (CFSI) which lead to the assigned RAG rating. This includes accountability and responsibility for the deployment of CFSI arrangements, including appropriate risk mitigation measures.
Overall, I have concluded that an inspection rating of AMBER, seek improvement, is appropriate. Areas of good practice were highlighted, and regulatory advice was provided in several areas which will be followed up via routine engagements. I acknowledge that further developments and improvements are planned.
Based on the selected samples examined, shortfalls were identified in the deployment of adequate quality management arrangements, including supply chain management arrangements.
I outlined ONR’s intent to raise appropriate regulatory issues (RI) to capture the identified areas for improvement and monitor the delivery of the remedial actions.
The licensee concurred with my findings and the overall RAG rating of this inspection, and considered the feedback provided was balanced.
Conclusion
Based on the evidence sampled, I conclude that a rating of amber, seek improvement, is appropriate to this inspection. Areas of good practice were highlighted, but it is acknowledged that further improvements are required to address the identified shortfalls. ONR regulatory issues will be raised to capture the identified areas for improvement and track remedial actions.