Date(s) of inspection
- November 2023
Aim of inspection
To seek assurance that Spent Fuel Services (SFS) and supporting organisations, e.g. Enterprise had adequately implemented the corporate arrangements for LC36 (Organisational capability).The intervention was justified in the ONR Spent Fuel Services Justification Document (2022/64238) and supports the ONR Sellafield Decommissioning, Fuel and Waste Advanced Gas Reactor Operating Programme Plan (2022/47759).
Subject(s) of inspection
- LC36 – Organisational capability – Rating: Amber
Key findings, inspector’s opinions and reasons for judgement made
I, supported by a Leadership and Management for Safety Inspector, undertook a Licence Condition (LC) 36 (Organisational capability) inspection at the Spent Fuel Services (SFS) operating unit at the Sellafield site. The inspection primarily focussed on the engineering and maintenance input to the nuclear baseline at SFS, but also sampled evidence of compliance within SFS itself.
The engineering and maintenance element of the SFS organisational baseline is delivered by Enterprise Plant Engineering and comprises around 200 posts, SFS itself has control of its own organisational baseline of around 370 posts, thus the engineering and maintenance element is around 35% of the SFS organisational baseline, most of these posts are on the nuclear baseline which is required to secure safe nuclear operations.
I found that an SFS change had been adequately completed and overall SFS is following the arrangements made under LC36. However, I found that the Enterprise Plant Engineering change sampled only had a rudimentary observance of the arrangements made under LC36; the related management meeting progressed while not quorate, there were significant objections raised by a key stakeholder and changes had been implemented prior to to the change process being approved. I also found that the reliability engineer cadre within SFS was understaffed by around 42%. The number of plant engineers was better with around 90% of positions filled. However, the shortfall in reliability engineers is significant in that these engineers address the longer term ageing management issues with the plant. ONR inspectors are aware of shortfalls with the numbers of engineers at the Sellafield Site and have written to the Licensee over this matter; nonetheless the shortfall in the number of engineers and the rudimentary observance of the arrangements made under LC36 merit an Amber rating and I intend to seek improvement.
Having considered the evidence presented during the inspection, I am of the opinion that SFS (principally via the input provided to SFS by Enterprise Plant Engineering) has not demonstrated an adequate level of compliance with the requirements of LC36. Under LC36(1), a licensee is required to have adequate human resources and under LC36(2), a licensee shall make and implement adequate arrangements to control any change to its organisational structure or resources which may affect safety. From an LC36(1) perspective, TIG 36 (Para 6.19) requires me to check for evidence of staff shortages that are not being filled; and from an LC36(2) perspective I am required to check that suitable controls to ensure that nuclear safety is not adversely affected have been identified and implemented (Para 6.24). I am of the opinion that the intent of these clauses and associated guidance has not been met. I did find the the MoCRA under the direct control of SFS was adequate, and that, notwithstanding some terminology deviations, SFS has a Control and Supervision Baseline and a Minimum Safe Manning Levels document in place that are current and have followed the relevant due process. However, overall I rate this inspection Amber and intend to seek improvement. This decision has been recorded in ONR-EDR-23-054.