The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Sellafield site licensee (Sellafield Ltd, SL) against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. In accordance with this strategy, an inspection of SL’s Intelligent Customer capability for the proposed 20-year Programme and Project Partners (PPP) contracts was carried out on 8th and 9th August 2018. The purpose of the inspection was to determine whether SL’s documented management arrangements meet relevant good practice.
A team comprising the ONR Corporate Inspector, Project Inspector and Nuclear Safety Inspector ‑ Leadership & Management for Safety carried out the inspection. The inspection focussed on the adequacy of SL’s Intelligent Customer arrangements as applied specifically to the proposed Programme and Project Partners (PPP) contracts.
The inspection comprised a review of relevant documentation supplied by SL in advance of, and during, the Inspection plus a group discussion with several members of SL’s Intelligent Client Core Team and individual discussions with two Heads of Profession (Construction and Design & Engineering), the Environment, Health, Safety & Quality (EHS&Q) Value Stream Lead from the Projects Delivery Directorate (PDD), and the Project Manager for the [Sellafield Product Residue] Store Retreatment Plant (SRP). ONR’s technical assessment guide NS‑TAST‑GD‑049 Revision 5 (Licensee Core and Intelligent Customer Capabilities) formed the basis for the inspection.
Not applicable as this was not a system based inspection.
I found that SL’s documented management arrangements covering the Intelligent Customer capability for the proposed PPP contracts continue to evolve ahead of placement of contracts with the four ‘Lot’ partners later in 2018-19. The arrangements refer extensively to the term ‘Intelligent Client’. I found that the arrangements for the SL Intelligent Client include a specific section with requirements that appear to align well with the principles described in NS-TAST-GD-049.
SL has established a fully populated Intelligent Client Team, including a number of Heads of Profession, some of whom will hold Intelligent Customer roles. This Lead Team comprises an Intelligent Client Core Team and a wider Intelligent Client ‘Virtual Team’, although not all 114 identified positions have full time Intelligent Client roles. I found that SL has already achieved its target that at least 80% of the Intelligent Client team members attend the relevant ‘Introduction to PPP’ training course ahead of contracts being placed with the Lot partners.
SL plans to embed personnel in the PPP Aligned Delivery Team (ADT) and they will therefore no longer be able to fulfil their current Intelligent Customer role, including delivery of the Tier 2 assurance function. These personnel will instead focus on implementation of the relevant management arrangements and, whilst they will undertake Tier 1 (self-verification) assurance, I found that responsibility for Tier 2 assurance will fall to the Heads of Profession and their smaller core teams.
A number of major projects are currently ‘in flight’, at different stages of maturity, which may be transferred into the ADT following award of the contracts to the Lot partners. I found that the Transition Plan for the SRP project was well developed providing ONR with confidence that the associated risks are understood and are being effectively managed.
I found SL’s documented management arrangements covering Intelligent Customer capability for the proposed PPP contracts to be broadly in line with relevant good practice, including ONR’s expectations (NS-TAST-GD-049). There was also evidence that the Head of Construction’s arrangements are well advanced, including plans for the training and competency assessment of resources delivering an Intelligent Customer role in this functional area. I found the arrangements in the other areas sampled (EHS&Q and Design & Engineering) to be less well advanced.
I found minor shortfalls in six areas of SL’s management arrangements: (i) The Head of Enterprise Plant Engineering is not identified as being part of the PPP Intelligent Customer capability despite having responsibility for accepting new assets from contractors on behalf of the licensee; (ii) There is a lack of clarity regarding which Heads of Profession hold which specific roles, responsibilities, accountabilities and authorities (R2A2); (iii) There is insufficient justification of the respective R2A2 for the EHS&Q component of the Intelligent Customer capability, including the relationship with the individual Heads of Profession for these areas; (iv) There is insufficient consideration of how posts with Intelligent Customer R2A2 are identified in the Nuclear Baseline, and how future organisational changes will be managed; (v) There is inadequate explanation of Intelligent Customer requirements in the ‘Introduction to PPP’ training course materials; and (vi) There is insufficient clarity in the Design & Engineering function regarding the intended future approach to Tier 2 assurance, and how it will be underpinned by suitable and sufficient capability and capacity. I have raised a Regulatory Issue for SL to correct these shortfalls.
I also made a number of other observations where I considered that SL could further improve its arrangements, including greater consistency in consideration of the Intelligent Customer requirements for nuclear security.
ONR and SL had a shared understanding of the work remaining to be done by SL to ensure readiness for award of the PPP contracts. ONR will maintain dialogue with the Head of Project Improvements & Intelligent Client Integration to ensure the identified necessary improvements are delivered and to gain additional regulatory confidence that SL has adequate arrangements for the Intelligent Customer capability for the PPP contracts
I consider that the licensee’s arrangements covering Intelligent Customer Capability for the proposed PPP contracts are adequate to ensure SL will meet relevant good practice with only minor shortfalls which I have addressed by raising a Level 4 Regulatory Issue. It is my opinion that an inspection rating of ‘Green’ (no formal action) is merited.