- Site: Sellafield
- IR number: 22-014
- 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 was carried out of the Beta Gamma Operating Unit within the Remediation Value Stream.
The purpose of this inspection was to confirm that Sellafield Limited is adequately implementing the licensee’s site-wide arrangements for compliance with LC36 (Organisational capability) in the Beta Gamma Operating Unit within the Remediation Value Stream.
In addition, during the inspection we sampled the compliance arrangements of the operating unit against the conventional health and safety (CHS) aspects of the Management of Health and Safety at Work Regulations. We focused on the provision of competent conventional health and safety advice and conventional health and safety risk profile of the operating unit.
Interventions Carried Out by ONR
The inspection was a planned LC36 intervention conducted at the Copeland centre in Whitehaven and was undertaken on 11 May 2022 by the ONR Site Inspector supported by a team of specialist inspectors. A representative of Sellafield Limited Nuclear Intelligence and Independent Oversight (NI&IO) function also participated. The intervention covered the following elements of LC 36:
- LC36(1) The licensee shall provide and maintain adequate financial and human resources to ensure the safe operation of the licensed site.
- LC36(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.
- LC36(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 formal ONR 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-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).
- HSG65: Managing for Health and Safety (2013).
- L153: Managing health and safety in construction (2015).
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;
- Conventional Health and Safety staffing and competences;
- Management of Change (MoC); and
- Determination and review of, and ensuring compliance with, Minimum Safety Manning Levels (MSMLs).
The scope and focus of the inspection took into account of intelligence gained from various ONR interventions.
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 LC36 inspection, we sampled evidence associated with Sellafield Limited’s compliance with its corporate arrangements and 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 there are a number of vacancies in the baseline, adequate assurance was provided that appropriate recruitment actions are underway. We were satisfied that the Beta Gamma Operating Unit’s nuclear baseline is being adequately managed.
- We attended the Plant Operations Control Centre (POCC) meeting, which covered a range of matters including the Nuclear Safety and Fire Safety Dashboards and considered sentencing of Condition Reports raised locally. Regulatory advice was offered in relation to seeking positive assurance during this meeting that facilities are adequately resourced to safely undertake planned activities.
- We reviewed documentation associated with two organisational changes. For the Change Record sampled, CR 7759, describing a local organisational change in the Beta Gamma Operating Unit, the corporate arrangements appear to have been adequately implemented. A minor anomaly was noted in that the attached Appendix 1, handover plan does not appear to be relevant to the subject Change Record. During the intervention Sellafield Limited raised a Condition Report, to ensure that the appendix is attached to the correct Change Record (CR7842). We confirmed by observation that the CR had been implemented in the Online People Management System (OPMS) and we were satisfied.
- For the Management of Change Risk Assessment (MOCRA) sampled, MOCRA – 7815 describing the future waste operating unit structure, we sampled training records and verified that the MOCRA Author is Suitably Qualified Experienced Person (SQEP). It was explained that this MOCRA is ‘work in progress’ and will be further developed in the next two to three months. It became clear that this MOCRA is more associated with the Waste Operating Unit and will have minimal impact on the Beta Gamma Operating Unit. We therefore did not further pursue this line of questioning during the inspection and the Site Inspector will instead follow this up as part of future routine regulatory interactions with the Wastes Operating Unit, as necessary.
- We inspected the Control and Supervision Organisation Baseline supplied ahead of the inspection and verified that it had been produced in line with the corporate arrangements. Facility management advised that this has been superseded by an updated paper, which was endorsed at the local Management Safety Committee. Evidence was provided that this has been approved by the Head of Operations for the Beta Gamma Operating Unit and the Head of Profession for Operations but not by the Head of Profession for Maintenance or the Training Manager. This is a minor shortfall against the licensee’s corporate arrangements . We judged that it is proportionate to raise a new level 4 (i.e. lowest level) Regulatory Issue (RI) to allow ONR to test that the documentation completes the required ‘due process’. This has been raised as RI-10789.
- We also inspected the documented  Minimum Safe Manning Level (MSML) and received assurance that the MSML was satisfied for all Beta Gamma facilities on the day of the inspection. We verified that the author has completed the required MSML SQEP Author training and that the paper had completed the required due process, including approval at the local Management Safety Committee.
- Whilst the Beta Gamma Operating Unit has established a separate, dedicated local Management Safety Committee, Management of Change documentation continues to be submitted to the Remediation Value Stream’s Management of Change Committee. We reminded Sellafield Limited of the requirement for the Management of Change Committee to periodically review the potential for cumulative effects of change.
The information gathered on organisation of CHS at a facility level, would inform future conventional health and safety strategic interventions at Sellafield Limited. The operating unit was not, therefore, rated for the adequacy of its arrangements for complying with aspects of the Management of Health and Safety at Work Regulations 1999.
Conclusion of Intervention
On the basis of the evidence sampled at the time of the inspection, we judge that the dutyholder has adequately implemented the licensee’s corporate arrangements for Licence Condition 36, with only one minor area for improvement identified. One Level 4 (i.e.; lowest level) Regulatory Issue has been raised to manage the implementation of the identified area for improvement.
Taking the above findings into account, and noting the ONR guidance on inspection ratings, we judge that Sellafield Limited has adequately implemented its arrangements for compliance with LC36 (Organisational capability) in the Beta Gamma Operating Unit within the Remediation Value Stream.
We therefore consider that an inspection rating of Green (No Formal Action) is merited.