Office for Nuclear Regulation

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Sellafield - Licence Condition 36 (Organisational Capability) Arrangements Inspection

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) Division.  In accordance with this strategy, a Licence Condition (LC) 36 (Organisational Capability) arrangements inspection was carried out, as planned, on 9-10 May 2017.  The purpose of the inspection was to determine whether SL’s written arrangements are adequate to ensure the site’s compliance with LC36.  Other inspections carried out by ONR examine the implementation of the site-wide arrangements in a particular context.

Interventions Carried Out by ONR

A team comprising the ONR Corporate Inspector for Sellafield and the Professional Lead for Human and Organisational Factors carried out the inspection.  The inspection focussed on SL’s arrangements for managing the nuclear baseline (the means by which the licensee demonstrates that its organisational structure, staffing and competencies are suitable and sufficient to manage nuclear safety) and for defining and securing the minimum safety manning level (MSML) on facilities.  The inspection comprised a review of relevant management system processes and records, a review of recent event data and assurance reports, discussion with the process owners for LC36 and also for LCs10 and 12 (training and competence), and a demonstration of SL’s Online People Management System software.  ONR’s technical assessment guides NS-TAST-GD-065 (Function and content of the nuclear baseline) and NS-TAST-GD-061 (Staffing levels and task organisation) formed the basis for the inspection.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable as this was not a system based inspection.

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

In respect of SL’s management of the nuclear baseline, I was satisfied that, of the nine principles contained in NS-TAST-GD-065, SL was able to provide evidence that eight of them are adequately addressed in its management arrangements.  In particular, SL was able to demonstrate that it has adequately identified the resources required for nuclear safety, including roles, responsibilities accountabilities and authorities, and for managing the associated changes to that resource. On this basis I propose to close-out the open Level 3 regulatory issue 1931.  The one principle in NS-TAST-GD-065 that, in my opinion, SL was unable to demonstrate compliance with, was Principle 8 (‘The licensee should have a process in place a process through which the nuclear baseline is derived and managed’).  SL has a process but it is out of date in that it refers to arrangements which are no longer relevant, for example in respect of resource justification and organisational design.  SL was aware of this shortfall and is planning to review and revise the relevant document.  I have raised a new regulatory issue at Level 4 to track SL’s progress in making the necessary updates.  I have also raised a regulatory issue at Level 4 for SL to demonstrate the ability of line management to understand and verify the achievement of competence.

In respect of MSMLs, I judged the recent revisions SL has made to its management process for identifying and securing the MSML to be appropriate in that it provides a link to the conservative decision-making process, strengthens requirements for reporting of challenges to, or breaches of, the MSML, and includes repeated challenges as a trigger for review of MSML assessment.  I am satisfied with the training and support being provided to MSML assessment authors and the approach the LC36 process owner is taking to adoption of the new standard.  I was also satisfied that there are appropriate prompts in existing processes for plant and organisational changes to trigger review of the MSML assessment   I identified some minor shortfalls in SL’s arrangements which I will address through a Level 4 regulatory issue.  This includes following-up to ensure that the expected improvements in the quality of MSML related event reporting is achieved in practice. 

Conclusion of Intervention

I consider that the licensee’s arrangements are adequate to ensure the site’s compliance with LC36 with minor shortfalls which I have addressed through three new level 4  regulatory issues.  Therefore it is my opinion that that an inspection rating of ‘Green’ (no formal action) is merited.