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 this strategy, a Licence Condition (LC) 36 (Organisational capability) compliance inspection of the Remediation Directorate was carried out, as planned, in March 2017. The Remediation Directorate was formed in 2016 to look after the value chain associated with decommissioning and waste management at SL.
The purpose of this intervention was for ONR to determine the adequacy of implementation of the licensee's formal arrangements for compliance with LC36. I focused on the evidence of compliance in the decommissioning facilities which form part of Remediation Directorate, as the provision of adequate human resources is central to the safe operation of these facilities and the delivery of the high hazard and risk reduction work at SL.
LC36 requires that the licensee provides and maintains adequate human resources to ensure the safe operation of the licensed site. On 23 March 2017, I carried out a planned one-day, on-site LC36 compliance inspection within the Remediation Directorate. I was accompanied by ONR's Sellafield corporate inspector. The inspection comprised discussions with SL staff, and reviews of plant records and other documentation. In carrying out this inspection, I used the following ONR guidance:
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.
My inspection focussed on the following topics:
With regard to MSMLs, I was satisfied that the Remediation Directorate has adequately implemented SL's corporate process for defining MSMLs. The Remediation Directorate is now updating its MSML assessments in line with ongoing changes to its organisational structure. Daily checks are made on compliance with the MSMLs. The Remediation Directorate has not recorded any breaches of its MSMLs since 2015. SL stated that it validates the MSMLs through emergency exercises, but in two exercise reports I sampled this was not apparent to me. I have therefore raised a Level 4 regulatory issue for SL to explain this to ONR at a future interaction.
With regard to the change process followed by SL in forming the Remediation Directorate in 2016, I was satisfied that SL adequately set out the purpose and scope of these changes. It did this through an initial 'principles paper' followed by a series of subordinate changes, aligned to SL's overarching value streams, which are ongoing. I judged the risk assessments supporting the changes to be suitable and sufficient. I consider the Remediation Directorate is adequately monitoring the status of these changes through a monthly dashboard.
I found that the Remediation Directorate's organisational baseline adequately defines the human resource it needs to manage nuclear safety through application of a nine box 'Suitably Qualified and Experienced Person' (SQEP) matrix. On a sample basis, I found the organisational baseline to be consistent with the change programme as examined above. The Remediation Directorate is further developing its nuclear baseline to provide greater clarity on the SQEP resource it possesses against future demand, which I consider good practice.
The next phase of the Pile 1 demolition project (removal of the diffuser) has been sanctioned and is due to commence in September 2017. However I found that SL could not adequately justify the resourcing for this phase of the project from a nuclear safety perspective. I have therefore raised a Level 4 regulatory issue for SL to explain this to me..
I consider that the licensee is compliant with its legal duties under LC36, with only minor shortfalls identified when compared with appropriate benchmarks. Therefore, it is my opinion that an inspection rating of Green (no formal action) is merited.