Office for Nuclear Regulation

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 2019/20 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 LC 36 (“Organisational capability”). I focused on sampling evidence of compliance in the Magnox Encapsulation Plant (MEP), Encapsulated Product Stores (EPS) and the Waste Encapsulation Plant (WEP), which form part of SL’s Spent Fuel Management – Operational Waste Facilities, since the provision of adequate human resources is fundamental to the safe operation of these facilities and supports the delivery of the high hazard and risk reduction work by SL.

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

Interventions Carried Out by ONR

Licence Condition 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 the MEP & EPS and WEP facilities. My inspection focused on:

The inspection comprised discussions with SL staff, review of records, and 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. SL was, however, unable to provide adequate evidence of a suitable and sufficient review of the MSML for WEP. SL is currently in the process of reviewing the MSML, in line with the proposed changes to the WEP Operators’ working pattern, and I consider that it is proportionate to raise a single Level 4 (i.e. lowest level) Regulatory Issue here to allow ONR to test that SL undertakes a suitable and sufficient review.  Follow-up will be managed as part of routine regulatory business.

My findings were shared with, and accepted by, SL 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 SL has adequately implemented its arrangements for LC 36 in the MEP & EPS and WEP facilities, with one minor area 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 here. A Level 4 (i.e. lowest level) Regulatory Issue has been raised to manage the implementation of the identified area for improvement.