Office for Nuclear Regulation

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Review of evidence against completion of Improvement Notice I/2015/ONR/PSJ/001, and compliance inspection of Licence Condition 36 (organisational capability)

Executive summary

Purpose of intervention

The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Sellafield site licensee (Sellafield Limited, SL) against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Programme. In accordance with that strategy, a Licence Condition (LC) compliance inspection of the Magnox Operating Unit (OU) was carried out, as planned, in October 2016. Additionally, an inspection was undertaken to confirm the accuracy of the licensee's statement that it had complied with the requirements of ONR's 2015 Improvement Notice (IN) I/2015/ONR/PSJ/001 relating to compliance with LC24 (operating instructions)..

The purpose of the compliance inspection element of this intervention was for the ONR to determine the adequacy of implementation of the licensee's formal arrangements for compliance with LC 36 (organisational capability) in the Magnox OU. I focused on the evidence of compliance within all main facilities within the OU, as the provision of adequate human resources to support all required plant activities is central to the safe operation of these facilities.

The purpose of the IN element of the intervention was to confirm that Items 2 and 5 (of a total of 6) within the schedule attached to ONR's Improvement Notice had been completed adequately by the licensee. As Items 1, 3, 4 and 6 had already been accepted as complete by ONR following earlier interventions, completion of these two remaining Items would then confirm that the licensee had complied with all actions required by the Notice.

Interventions Carried Out by ONR

Improvement Notice I/2015/ONR/PSJ/001 requires that the licensee addresses shortfalls in its quality of, and adherence to, written instructions covering plant operations, and specifically where these relate to limits and conditions that are safety case claims. On 11 October 2016, I carried out a planned one-day, on-site inspection within the Magnox Reprocessing Facility, focusing on the completion of actions required by this IN. The inspection comprised discussions with SL staff, reviews of plant records and other documentation, and a plant walk down.

LC 36 requires that the licensee provides and maintains adequate human resources to ensure the safe operation of the licensed site. On 13 October 2016, I carried out a planned one-day, on-site LC 36 compliance inspection within the Magnox OU. The inspection comprised discussions with SL staff, and reviews of plant records and other documentation. In carrying out this inspection, the following ONR guidance was used:

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 my inspection, I sampled evidence of the work undertaken by the licensee to comply with Items 2 and 5 within the Schedule of the IN. Based on the evidence I sampled, which related to the adequacy of written alarm response instructions and of operating instruction compliance record sheets, I agree that the licensee has complied with the requirements of Items 2 and 5 of the Schedule. Given that previous interventions have confirmed that the licensee has already complied with the other four Items within that Schedule, the licensee has now therefore, complied with the entire Schedule.

In consequence, following a period of enhanced regulatory oversight by ONR, supported by the issuing of an IN, I consider that Magnox Reprocessing Facility has now achieved sustained compliance with the expected legal standard. I have updated the related ONR Regulatory Issue which has tracked the licensee's activities in addressing this shortfall and will propose this for closure.

I also looked at how SL assures itself of the provision of adequate human resources within the Magnox Operating Unit (OU). Adopting a sampling approach, I focused on identification of the resources important to safe operation, the effectiveness of controlling changes that might impact on safety and recent events where resource availability could have impacted the safety of operations within the OU.

In my opinion, as well as seeing evidence of adequate compliance with SL's formal arrangements, I noted a good practice whereby the licensee had utilised information from its reactive decision-making in order to develop a coherent protocol for safely managing a key facility during short-notice reductions in available resource.

I consider that the licensee is compliant with its legal duties under LC36, and that there are only limited opportunities for further ALARP improvements. Therefore, it is my opinion that an inspection rating of Green (no formal action) is merited.

From those areas sampled, I did not identify any significant shortfalls in the licensee's formal arrangements for compliance which would prompt a further inspection of those arrangements earlier than currently planned.

Conclusion of Intervention

From the evidence sampled during my Improvement Notice Schedule inspection, I judge that the requirements of the related Schedule have now been fully met, and that ONR should inform the licensee and wider stakeholders that the intent of the Notice has been achieved within the required timescales and that ONR should close its related Regulatory Issue.

There are no matters to be taken forward arising from my LC36 compliance inspection.