- Site: Sellafield
- IR number: 22-041
- Date: July 2022
- LC numbers: 36
Purpose of Intervention
In accordance with the Office for Nuclear Regulation’s (ONR’s) Sellafield Strategy, each year ONR performs a series of planned compliance inspections of selected licence conditions, targeted at those facilities with significant importance to nuclear safety. One such inspection was performed to assess the Special Nuclear Materials (SNM) Value Stream’s compliance with Sellafield Limited’s corporate arrangements for Licence Condition 36 (Organisational Capability).
Interventions Carried Out by ONR
With Leadership and Management for Safety specialist inspector support, I carried out a LC36 compliance inspection of the SNM North and South facilities on the 12 July 2022 at the Sellafield Site in Cumbria. 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.
The intervention was performed in line with ONR’s guidance requirements (as described in our technical inspection guides) in the areas inspected.
The inspection focused on:
- Sellafield Limited’s nuclear baseline for the SNM Value Stream (i.e. the means by which Sellafield Limited demonstrates the adequacy of its organisational structure, staffing and competencies to manage nuclear safety);
- The change process followed by the SNM Value Stream when implementing changes to the organisational structure for the SNM North and South facilities; and
- Sellafield Limited’s compliance with the licensee’s arrangements for determining, and ensuring compliance with, Minimum Safety Manning Levels (MSMLs) for the SNM North and South facilities.
The inspection comprised discussions with Sellafield Limited staff, review of records, and sampling of information contained within electronic databases and other documentation.
Key Findings, Inspector’s Opinions and Reasons for Judgements Made
Evidence was seen that SNM is maintaining, and has an adequate understanding of its nuclear baseline. SNM reported progress in reducing the number of nuclear baseline vacancies since this was inspected in June 2022 as part of the CNI inspection. Currently 22% of nuclear baseline positions have actual, or likely future vacancies. I reminded SNM that it is important that it remains vigilant in effectively managing the vacancies for both current and future programmed activities.
For two organisational changes, I inspected that Suitably Qualified and Experienced Persons had written adequate management of organisational change justifications, and that due process had been followed. This included consideration by quorate Management of Change Committees. I also inspected that the changes had been appropriately implemented on the baseline.
I found that the SNM(S) Control and Supervision Organisation Baseline had been produced in line with Corporate arrangements. I had verified that this was the situation for SNM(N) following a December 2021 Inspection. I inspected the four SNM Minimum Safe Manning Level (MSML) papers and found that they had all been subject to consideration by the relevant Management Safety Committee. For two of the MSML papers, SNM could not demonstrate that the authors had completed the training required by the corporate requirements. Assurance was provided by the Head of Operations SNM(S) for why he had confidence in the MSML results described in the papers. I judged this matter represented a minor shortfall.
Conclusion of Intervention
On the basis of the evidence sampled at the time of the inspection, I judge that Sellafield Limited has adequately implemented its arrangements for LC36 in the SNM Value Stream. Noting the ONR guidance on inspection ratings, it is my opinion that an inspection rating of Green (no formal action) is merited here.