Office for Nuclear Regulation

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LC 36 Licence Compliance Arrangements Inspection

Executive summary

Purpose of intervention

The Office for Nuclear Regulation (ONR) undertakes all regulatory interactions with Sellafield Limited (SL), the site licensee, against a strategy defined by the ONR Sellafield Programme.  The planned inspection schedule for the current regulatory year (covering April 2015 – March 2016), the content of which is guided by that strategy, identifies the Licence Conditions (LCs) that will be inspected over this period.

This planned intervention was undertaken to determine the adequacy of the arrangements made by SL to comply with licence condition 36 (LC36). Sellafield is a large and complex site with high levels of human resources; however correct deployment of competent human resources to meet all of Sellafield’s many nuclear safety requirements, and adequate oversight of the process for doing so, are key nuclear safety requirements. 

Interventions Carried Out by ONR

The inspection concerned Licence Condition LC36(1) which requires that: “The licensee shall provide and maintain adequate … human resources to ensure the safe operation of the licensed site”.  It comprised interviews and examination of documents. Interviews included those with managers involved in developing these arrangements, with the Sellafield Environment, Health, Safety and Quality (EHS&Q) Director designate, and a sample of people with resource management responsibilities, including two Heads of Operations and one representative of a professional group.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable; this was not a Safety System inspection.

Key Findings, Inspector's Opinions and Reasons for Judgements Made

I consider SL’s arrangements for LC36(1) to be progressing well but still incomplete. There are now governance structures in place to oversee the capacity of human resources, and heads of profession are in place to oversee capability. The managers we interviewed were able to give a good account of how they ensure adequacy of human resources, and were clear about the company’s expectations that resources must remain adequate for safety. There are tools in advanced development that should give transparency and assist rigour in the management of the human resources once these are complete and fully functioning.  Specifically, SL is rolling out its Online People Management System (OPMS) database and knowledge management (KM) arrangements. OPMS will give live information to help manage human resources, including approved staffing levels, competence requirements for posts, and the qualifications of people in post. KM arrangements include requirements for Heads of Profession to identify and manage vulnerabilities in specialist areas such as singleton posts and demographic problems, and where these require succession planning (i.e. for key roles).

However the OPMS database was not yet fully functioning at the time of the inspection; in particular many of the more important users such as managers in operational areas were not yet able to interrogate the system to see important information such as the qualifications of staff, and there was still a small proportion (around 5%) of data still to input. Also, the KM arrangements, which will be an important part of providing resilience to the organisation and of meeting relevant good practice, were in an early stage of implementation. Ensuring that OPMS is populated and more usable is a key next step.

Conclusion of Intervention

My findings were shared with, and accepted by, the licensee as part of normal inspection feedback.

It is my opinion that SL has made great progress in improving its LC36(1) arrangements at a time when organisational pressures and changes mean that they are likely to be tested. However it is my opinion that an IIS rating of 4 (below standard) is appropriate until the OPMS database and KM arrangements are fully implemented and functioning.

There is an existing ONR Regulatory Issue concerning lack of demonstration of adequacy of human resources at Sellafield (RI 1931).  As a result of this inspection I do not see a need to add any further RI on account of my findings here.  Instead RI 1931 should remain open for the time being and be revisited later this year to establish whether suitable progress has been made so that it can be closed.