Office for Nuclear Regulation

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Planned 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) Division. The planned inspection schedule for 2020/21, updated as a result of the COVID-19 Pandemic, identifies the Licence Conditions (LCs) that will be inspected during this period.

The purpose of this inspection was for ONR to determine the adequacy of implementation of SL’s arrangements for compliance with Licence Condition (LC) 36 (“Organisational capability”). I focused on sampling evidence of compliance in the Oxide Fuel Storage Group (OFSG) since the provision of adequate human resources is fundamental to the safe operation of the facilities included within the OFSG span of operations.

The overall adequacy of SL's site-wide LC 36 arrangements is considered separately in other ONR interventions.

Interventions Carried Out by ONR

LC 36 requires that the licensee provides and maintains adequate financial and human resources to ensure the safe operation of the licensed site.

I carried out a planned LC 36 compliance inspection of OFSG. The inspection focused on:

The inspection comprised discussions with SL staff, a review of records, and the sampling of information contained within electronic databases and other documentation.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable since this was not a safety system based inspection.

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

No significant matters were identified as requiring immediate regulatory attention in relation to the implementation of the LC 36 arrangements at OFSG. I noted one particular area of good practice in relation to how OFSG had undertaken a Change Record, which at face value I consider this Change Record to have been a good model for both stakeholder engagement and the approach for analysing options for changes to staff numbers and working patterns. Two minor shortfalls were identified and these will be followed up as Level 4 (i.e. lowest level) issues as part of routine regulatory business. I observed one matter of potential concern in relation to the minutes of a Management of Change Committee meeting for a different area of Sellafield and will draw this to the attention of the ONR Sellafield Corporate Inspector for consideration.

I provided regulatory advice to OFSG in relation to the raising of condition reports when plant parameters were recorded as being out of specification.

My findings were shared with, and acknowledged by, OFSG’s management as part of normal inspection feedback.

Conclusion of Intervention

On the basis of the evidence sampled at the time of the inspection, I judge that OFSG has adequately implemented SL’s arrangements for LC 36, with two minor areas for improvement identified. Noting the ONR guidance on inspection ratings, it is my opinion that an inspection rating of Green (no formal action) is merited. Two Level 4 (i.e. lowest level) Regulatory Issues have been raised to manage the implementation of the identified areas for improvement.