Office for Nuclear Regulation

Remote 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 Retrievals value stream since the provision of adequate human resources is fundamental to the safe operation of the facilities included within the Retrievals span of control.

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 Retrievals. The inspection focused on:

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

Explanation of Judgement if Safety System Not Judged to be Adequate

This section is not applicable.

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 Retrievals.  I noted two particular areas of good practice in relation to how Retrievals manages changes to its organisation including the management of phased changes and challenge to change proposals at the Management of Change Committee (MOCC).  I identified a separate matter for follow-up via a Level 4 (i.e. lowest level) regulatory issue concerning the cumulative effect of organisational change.

I gave regulatory advice to Retrievals in relation to: 1) ensuring the continued quorate of MOCC meetings; and 2) ensuring that Management of Change Risk Assessment (MoCRA) implementation actions are formally identified and tracked in accordance with SL’s arrangements.

My findings were shared with, and acknowledged by, Retrievals 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 Retrievals has adequately implemented SL’s arrangements for compliance with LC 36.  Noting the ONR guidance on inspection ratings, it is my opinion that an inspection rating of Green (no formal action) is merited.  One matter was identified for follow-up via a Level 4 (i.e. lowest level) regulatory issue concerning the cumulative effect of organisational change.