Sellafield - Inspection ID: 52967 | Office for Nuclear Regulation

Executive summary

Date(s) of inspection: August 2024

Aim of inspection

To gain confidence that Sellafield Ltd. has made sufficient progress against the actions and key themes of the Fire Safety Improvement Plan (FSIP) to support closure of Level 2 Regulatory Issue actions.

This intervention aims to collect evidence against the following actions:

7. Fire safety performance measurement and strategic improvement

Sellafield Limited to demonstrate that fire safety performance is measured, that trends are identified and escalated and that senior leaders have sufficient understanding of fire safety performance in their areas to enable delivery of strategic improvements.

8. Training, capability and strategic oversight

Sellafield Limited to demonstrate that senior leaders are sufficiently trained to deliver their fire safety responsibilities, that senior leaders have adequate strategic oversight of training needs (e.g. for reliability engineers working on fire systems) and that key operational personnel (such as building managers) have sufficient training and capability to deliver the full scope of their fire safety responsibilities.

Subject(s) of inspection

Fire (Life Safety) Compliance Inspection - Rating: Green
LC10 - Training - Rating: Green
LC36 - Organisational capability - Rating: Green

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

This intervention was undertaken as part of the 2024/25 series of planned internal hazards and fire safety inspections. The aim of this specific activity was to gain confidence that Sellafield Ltd. has made sufficient progress against the actions and key themes of the Fire Safety Improvement Plan (FSIP) to support closure of Level 2 Regulatory Issue (RI-11266) actions.

The main focus of this intervention was safety management with respect to life and nuclear fire safety. We undertook interviews with middle and senior leaders as part of the intervention, seeking to gather evidence on their understanding of their roles and responsibilities with respect to fire safety, the Sellafield Fire Safety Improvement Plan and effective safety leadership and culture.

By doing so, this intervention sampled SL’s compliance with:

Nuclear Site Licence Conditions LC10 (Training) and LC36 (Organisational capability);
the Regulatory Reform (Fire Safety) Order 2005, parts: 11 (Fire safety arrangements); 13 (Fire-fighting and fire detection); 18 (Safety assistance); and 21 (training).

Our questions and judgement were informed by relevant good practice including:

ONR Technical Assessment Guide NS-TAST-GD-107 - Safety leadership
ONR Technical Assessment Guide NS-INSP-GD-070 - Organisational culture guide for inspectors

In addition, compliance with the Regulatory Reform (Fire Safety) Order 2005 was sampled in the Sellafield Limited Estates Function. This included a walkdown of B512, an emergency equipment store managed by Estates and interactive question session with relevant building managers.

Based on the areas sampled, we identified no specific shortfalls with respect to compliance with LC10 or LC36, or the above mentioned parts of the Regulatory Reform (Fire Safety) Order 2005. The intervention is therefore rated green against these items. Some areas were found where, although legally compliant, SL could improve their arrangements. In these instances we gave advice as detailed below.

The inspection findings have also been reviewed against ONR Technical Assessment Guide (TAG) NS-TAST-GD-107 ‘Safety leadership’. Some areas of strength identified in the TAG are evident, for example:

At FGMSP, safety has been given priority by senior leaders, despite this having significant impacts on delivery.
One leader commented that if in the event of a report of poor safety behaviour, in the first instance they would want to understand what circumstances had led to this, rather than seeking to attribute blame.
There was widespread awareness that senior leadership monitoring of safety performance, where possible using leading indicators, is key to securing high and sustained standards.
There was widespread appreciation of the importance of rewarding and recognising good safety performance.
The importance of having a strong reporting culture was understood.
The importance of prioritising and targeting actions and resource based on safety risk was widely understood, although deciding how best to do this is a key challenge for Sellafield Ltd.

We also reviewed the findings of this intervention against ONR Technical Inspection Guide (TIG) NS-INSP-GD-070 ‘Organisational culture guide for inspectors’. This TIG identifies safety culture warning flags that inspectors may find during their interventions. In general, we found evidence that with respect to fire safety, SL has historically experienced a number of problem areas that resonate with cultural red flags identified in the TIG. Since the L2 regulatory issue on fire safety was raised the position has improved, however at this inspection evidence was found that suggests that in the areas sampled, the following warning flag remains an issue:

Deviation from standards and behaviours – evidenced by non-compliance with mandatory building evacuation instructions and unauthorised items left in buildings.

This intervention was themed around two of the outstanding actions in Level 2 Regulatory Issue:

7. Fire safety performance measurement and strategic improvement

8. Training, capability and strategic oversight

For Action 7 we identified significant evidence of good progress including:

Clear escalation routes have been established for Fire Risk Assessment findings. This has been embedded over the past 18 months and the business is effectively reacting to findings e.g. discussing Amber and Red FRA’s at Fleet call and actioning appropriately.
All senior leaders interviewed were aware of the escalation route, specific escalated issues and how action had been taken when safety goals were at risk.
There is a clear route for fire performance data to reach value stream and executive committees and evidence that the safety and programme implications of fire safety issues is incorporated into strategic decision making.
Development of Fire Safety metrics on the Safety Baseline Measures dashboard Plan Of The Week to give Directors, Heads of OU and Heads of Operations visibility on progress of key improvements e.g. POCC dashboard alignment, FRA action close out and in-line assurance activities.
Standardisation of POCC dashboards at facility level is taking place with around 50% of facilities having done so and the remaining 50% on track. This is a metric measured as part of the Safety baseline measures and so given adequate priority and Senior Leaders recognise the importance of this task.
Increased uptake in In The Line Assurance activities where dutyholders/programme leads have identified Fire Safety as a key assurance topic for the financial year. 9 activities carried out in 2023/24, 29 already scheduled/complete for 2024/25.
Introduced performance snapshots produced by FP team, which are sent to dutyholders and Value Stream leads on a quarterly basis, giving an indication of fire protection ‘health’.

We identified that there remains work to be done on data availability across digital systems and development of leading indicators. Sellafield demonstrated awareness of these gaps and have captured these within dedicated Enterprise Safety Improvement Plan strands. This includes development of a catalogue of Fire Protection metrics utilising leading and lagging indicators.

We judge that there is likely sufficient evidence to close action 7 and this will be progressed through further engagement with Sellafield Limited and ONR governance processes.

For Action 8 we identified positive evidence including:

In the Estates function building manager capability and capacity has improved such that better fire safety management across several hundred buildings is now possible.
Building managers interviewed demonstrated a strong understanding of their fire safety roles, evidenced the training they had received and the ongoing support available.
Operational and senior leaders interviewed understood fire safety roles and responsibilities.

However, we also identified:

For operational leaders fire safety understanding is largely developed through response to incidents and enforcement.
A high degree of importance is given to the new fire safety masterclass programme and this has received good feedback from attendees. However, this programme is ad hoc and not enshrined in any arrangements. There is no requirement for individuals given significant fire safety accountability ‘through the line’ to receive this or similar training or to refresh this at any point.
There is currently no demonstration that fire safety training improvements (for operational and strategic leaders) are embedded or will result in sustained improvement in competence.

We judge that further work is required to embed improvements in this area. This will be addressed in ongoing FSIP engagements.

Conclusion

Based on the areas sampled, we identified no specific shortfalls with respect to compliance with LC10 or LC36, or the above mentioned parts of the Regulatory Reform (Fire Safety) Order 2005. The intervention is therefore rated green against these items. Some areas were found where, although legally compliant, Sellafield Ltd could improve their arrangements. In these instances we gave advice as detailed below.

At FGMSP, safety has been given priority by senior leaders, despite this having significant impacts on delivery.
One leader commented that if in the event of a report of poor safety behaviour, in the first instance they would want to understand what circumstances had led to this, rather than seeking to attribute blame.
There was widespread awareness that senior leadership monitoring of safety performance, where possible using leading indicators, is key to securing high and sustained standards.
There was widespread appreciation of the importance of rewarding and recognising good safety performance.
The importance of having a strong reporting culture was understood.
The importance of prioritising and targeting actions and resource based on safety risk was widely understood, although deciding how best to do this is a key challenge for SL.

Deviation from standards and behaviours – evidenced by non-compliance with mandatory building evacuation instructions and unauthorised items left in buildings.