- Site: Sellafield
- IR number: 22-017
- Date: May 2022
- LC numbers: 36
Purpose of Intervention
The Office for Nuclear Regulation (ONR) undertakes all regulatory interactions with the Sellafield site licensee (Sellafield Limited) against a strategy defined by the ONR Sellafield Subdivision. In accordance with this strategy, a planned Licence Condition (LC) compliance inspection against LC36 (Organisational Capability) was carried out on the Magnox Reprocessing Facility (MRF) operated by Sellafield Limited.
The purpose of this inspection was to confirm that Sellafield Limited is adequately implementing the licensee’s site-wide arrangements in compliance with LC36 within the Magnox Reprocessing Facility.
Interventions Carried Out by ONR
The inspection was a planned LC36 intervention conducted at the Magnox Reprocessing Facility and was undertaken on 11th May 2022 by the ONR Site Inspector supported by an ONR specialist developing inspector. A representative of Sellafield Limited Nuclear Intelligence and Independent Oversight (NI&IO) function also participated. The intervention covered the following elements of LC36:
- LC 36(1) The licensee shall provide and maintain adequate financial and human resources to ensure the safe operation of the licensed site.
- LC 36(2) Without prejudice to the requirements of paragraph 1, the licensee shall make and implement adequate arrangements to control any change to its organisational structure or resources which may affect safety.
- LC 36(5) The aforesaid arrangements shall provide for the classification of changes to the organisational structure or resources according to their safety significance. The arrangements shall include a requirement for the provision of adequate documentation to justify the safety of any proposed change and shall where appropriate provide for the submission of such documentation to ONR.
As part of the preparation for the delivery of this intervention, the following guidance documentation was used:
- ONR-INSP-GD-059 Revision 8 Guidance for Inspection Strategy Planning and Recording;
- NS- TAST-GD-065: Function and Content of the Nuclear Baseline, Revision 4 (August 2018);
- NS-INSP-GD-036: Organisational Capability, Issue 1 (March 2021);
- NS-TAST-GD-048: Organisational Change, Revision 6 (September 2018); and
- Nuclear Baseline and the Management of Organisational Change (A Good Practice Guide produced by the cross-industry Organisational Capability Working Group and published on behalf of the Nuclear Industry Safety Directors Forum), Issue 3 (March 2017).
The inspection comprised discussions with Sellafield Limited personnel and a review of a targeted sample of Sellafield Limited documentation.
The inspection focused on the following areas:
- Review and maintenance of the Nuclear Baseline, the means by which Sellafield Limited demonstrates the adequacy of its organisational structure, staffing and competencies to manage nuclear safety;
- Determination and review of, and ensuring compliance with, Minimum Safety Manning Levels (MSMLs); and
- Management of Change (MoC).
The scope and focus of the inspection took into account intelligence gained from previous ONR interventions involving MRF.
Explanation of Judgement if Safety System Not Judged to be Adequate
This was not a system-based inspection, and therefore no judgement has been made of the adequacy of implementation of any part of the safety case.
Key Findings, Inspector’s Opinions and Reasons for Judgements Made
During the inspection, I sampled evidence associated with Sellafield Limited compliance with its LC 36 corporate arrangements and the implementation of these arrangements; I concluded the following:
- During the inspection, the licensee demonstrated that it has an adequate understanding of its nuclear baseline, which it is actively managing to accommodate both recent and future anticipated changes to its business. While a number of vacancies on the baseline were identified, adequate assurance was provided that appropriate recruitment programmes are underway and an organisational restructuring initiative is planned to make more efficient use of existing resources to meet requirements. I was satisfied that the Magnox Reprocessing Facility’s nuclear baseline is being adequately managed.
- I inspected tracker documentation and Condition Reports raised against the Minimum Safe Manning Level (MSML). Although breaches were identified, I was satisfied with the recorded decision making processes undertaken to risk assess the breaches and address them by installing appropriate mitigation.
- I reviewed documentation associated with two organisational changes. I was satisfied that the changes were appropriately categorised, had followed the correct Management of change process for implementing the arrangements for organisational change and noted no safety concerns as a result of the changes.
- I gathered information on the progress of preparations for the transition of MRF from Operations to Post Operational Clean Out (POCO). I was satisfied with the approach being taken and noted that learning from the previous THORP plant transition was being applied. I provided a single point of advice to the licensee on expediency of leadership decision making and clear communication of the outcomes with the workforce affected by the decision.
Conclusion of Intervention
On the basis of the evidence sampled at the time of the inspection, I find that Sellafield Limited is undertaking adequate implementation of the licensee’s site-wide arrangements in compliance with Licence Condition 36.
I therefore judge that an inspection rating of Green (No Formal Action) is merited.