Executive summary
Date(s) of inspection: February 2024
Aim of inspection
The aim of the inspection is to assess the adequacy of Sellafield's arrangements for carrying out Malicious Actions Assessments (MAAs). Gaining assurances in this area, will enable ONR to reduce the regulatory burden by taking a sampling approach to MAAs as they are carried out in the future.
Subject(s) of inspection
- FSyP 6 - Physical Protection Systems - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
Whilst the primary focus of the intervention was to gain assurance around the adequacy of Sellafield Limited’s (SL’s) written arrangements for carrying out Vital Area Identification (VAI), locally termed Malicious Actions Assessments (MAAs) by SL, focus was also given to the team’s resourcing, and the applicability and influence of MAAs to the Physical Security Vulnerability Assessment (PSVA) process. Furthermore, the intervention examined, in limited detail, the MAA team’s application of the Vital Area Identification (VAI) parameters pertaining to the Sellafield Project and Residue Store Retreatment Plant (SRP).
MAAs provide key security underpinnings. If they are not properly identified then it is likely that insufficient, ineffective or inappropriate physical protection systems (PPS) and protective security arrangements will be implemented in attempts to mitigate public risk.
This scope serves to inform my initial judgement around the MAA arrangements, including their application, sustainability, and relevance to the wider security processes, to ensure the appropriate security outcomes are met in line with the Security Assessment Principles (SyAPs). However, the breadth of this scope also serves to identify any aspects of SL’s MAA arrangements which require detailed regulatory scrutiny before making a final recommendation that ONR move toward an enhanced sampling regime for MAA submissions.
I consider the written arrangements (Security and Resilience Technical Assessment Notes - S&RTANs 1-4) to be complete and meet their stated purposes as a set of ground rules and knowledge capture. Furthermore, it is my opinion that the scrutiny the S&RTANs continue to receive within the MAA team is positive, reflecting the ongoing pursuit of improvement and validation. However, despite the assurances obtained, the arrangements remain in draft form, and a more detailed examination of the application of the arrangements is required.
My high-level examination of the application of MAA analyses within the SRP, provides me with some confidence around the application of the VAI parameters, in alignment with our expectations. However, this intervention did not, owing to time restrictions, include a detailed scrutiny of the nuanced application of specific input parameters. It is the intention of ONR STAR to conduct a follow-up intervention in the third or fourth quarter of 2024 whereby the status of the MAA arrangements can be reviewed alongside a detailed assessment of their application against a sampled facility.
To sample SL’s compliance in terms of carrying out MAAs, I identified numerous facilities undergoing recent ‘activity’, and likely requiring MAAs to be conducted. The MAA team was able to demonstrate a complete compliance across the facilities. I am satisfied through this process that the site-wide coverage and compliance with MAA requirements is adequate. Enquiring as to whether any MAAs have been missed historically, the dutyholder was forthcoming in identifying a facility, the Silo Maintenance Facility (SMF) whereby an error was made. However, I am satisfied that mitigations have been put in place in support of continual improvement to prevent reoccurrence.
Personnel resource within the team is limited, and strained by the demands placed upon it from historic workload, plus ongoing and planned site-wide activities. Whilst there are organisational mechanisms to respond to future personnel losses, it is acknowledged that the role profile within the team is niche and challenging to fulfil within the wider internal pool of potential applicants. External options are limited owing to organisation recruitment policy limitations. However, currently the team has the capability to meet foreseeable demand, which is enhanced by its involvement in wider governance meetings, namely the SL Bimonthly Management Meeting as a mechanism to plan and prioritise. Furthermore, a key member of staff will be returning to the team in July 2024. It is my opinion that despite the team meeting its objectives, risks around resilience do exist. However, it would be imprudent to allow issues beyond the team’s control to disproportionately influence my assessment of the arrangements that are in place.
An examination of the MAA’s application in underpinning PSVAs demonstrates an integrated approach involving all key stakeholders. It is my judgement that the relevant expertise and knowledge is consulted and this two-way promotion and initiation of the MAA process facilitates development and utilisation. Whilst the processes as part of wider strategic engagement are still developing, namely in respect of Civil Nuclear Constabulary (CNC) involvement, there is evidence to suggest there is an adequate network of vested parties already established to ensure that PSVAs are adequately informed and contextualised by MAAs.>
This inspection provides significant assurance and confidence in the dutyholder’s arrangements. I have awarded a GREEN rating for this intervention. However, in order to make a recommendation for ONR to take a sampling approach in the future, an additional inspection with detailed focus upon the application of the arrangements is required. The current draft status of the MAA arrangements further prevents a formal judgement from being made.
Although this intervention focusses on the adequacy of the MAA arrangements, wider, relevant issues are explored in varying degrees of detail. As a result, it is recommended that ONR Civil Nuclear Security and Safeguards (CNSS) utilise this IR to inform its current understanding of SL’s processes and procedures relevant to security. In particular, aspects of this intervention are relevant to governance, organisational learning, assurance, security culture and vulnerability assessment.
Conclusion
At a high level I consider the written arrangements [5] are complete and represent a sufficient breadth of technical content. In my opinion the four documents cover the most relevant themes within the MAA process, and represent an adequately-scoped set of ground rules and knowledge capture.
However, a detailed assessment of the application of the MAA arrangements, namely the assessment of the nuanced calculations at a suitable facility is required to enable a judgement to be made into the adequacy of SL’s MAA arrangements and ONR’s future assessment strategy. This will be scheduled in due course.
At a high-level, the S&RTANs 1-4 cover the relevant VAI parameters (as defined in Endnote 1), and rely upon the RGP expected by ONR, namely figures derived from the U.S. Department of Energy (DoE) Handbook [7]. The MAA team are actively engaged with relevant research and are invested in ongoing testing to further inform the data ,underpinning their MAA calculations. The scrutiny the S&RTANs continue to receive within the MAA team is positive, reflecting the ongoing pursuit of improvement and validation. It is clear that the team as a whole understand and contribute to the written arrangements and continue to challenge assumptions.
Whilst it is my judgement that this activity will not affect the nature and extant status of the arrangements as an internal tool, the draft status of some of the documents further prevents ONR STAR from making a finalised judgement against them.
I was able to gain evidence to demonstrate that MAAs are applied at facilities where intended. Despite identifying one facility where an MAA was mistakenly missed, I was reassured by the mitigations that have been put in place in support of continual improvement to prevent reoccurrence.
The MAA team has limited personnel resource but the members of the team are Suitably Qualified and Experienced Personnel (SQEP), and are meeting demands placed upon them. This was evidenced by ONR STAR’s scrutiny of the ‘live submissions sheet’[7]; a sampling of facilities; and that of the governance taking place within the SL Bimonthly Meeting. The team has demonstrated transparency in terms of applying lessons learnt to continually improve and avoid shortfalls.
An examination of how the MAAs underpin the PSVA process demonstrates an appreciation of the wider security procedures and the promotion of the MAA process in an integrated manner. The engagement with a breadth of stakeholders ensures an adequate degree of facility and site-wide knowledge is obtained to provide important context, particularly around developing and applying threat scenarios (elements pertinent to the latter have been identified for detailed assessment as part of ONR’s planned intervention of an MAA submission against a specified facility in the future).
Stakeholders are engaged following the formal identification of security-related training needs, with MAA team representation, and the appointment of security personnel. The MAA team’s representation in PSVA review committees allows for a joined-up approach and breadth of consultation. Furthermore, the active participation of the CNC, which continues to evolve, informs their nuanced patrol strategy.
I have awarded a GREEN rating for this inspection. However, without the formalisation of the written arrangements, and a more detailed assessment of the application of nuanced calculations, this rating cannot extend to a recommendation that ONR move to an enhanced sampling regime for MAA submissions at this point in time. A follow-up intervention will be required, and arranged in due course.
Whilst the arrangements themselves appear complete, fit for purpose and well-maintained, they do remain in draft form. This intervention provides a degree of assurance in SL’s MAA arrangements including the team’s awareness and agreement upon them. However, ONR’s formal assessment of these arrangements is not possible until they have been governed and formalised, albeit internally, noting the limited site-wide relevance.
To sample SL’s compliance in terms of carrying out MAAs, I identified numerous facilities undergoing recent ‘activity’, and likely requiring MAAs to be conducted. The MAA team was able to demonstrate a complete compliance across the facilities. Where MAAs were not undertaken, a satisfactory response was provided as to why. I am satisfied through this process that the site-wide coverage and compliance with MAA requirements is adequate. Enquiring as to whether any MAAs were missed historically when required, the dutyholder was forthcoming identifying a facility, the SMF, where an error was made. However, I am satisfied that mitigations have been put in place in support of continual improvement to prevent reoccurrence.
A general application of the VAI parameters, the dutyholder’s application of RGP, and its utilisation of the UK DBT was examined at a high level. Whilst this provided a degree of assurance in the application of the MAA arrangements, without a detailed analysis of this application at a sampled facility, ONR STAR is unable to confirm that adequacy has been achieved.
It is the intention of ONR STAR to conduct a follow-up intervention in the third or fourth quarter of 2024 whereby the status of the MAA arrangements can be reviewed alongside a detailed assessment of the application against a sampled facility. This will complete ONR STAR’s formal assessment and strengthen the basis for which to make a judgement about the merits for a sampling approach in the future.