Office for Nuclear Regulation

Follow-up inspection of Intelligent Customer Capability for the Programme and Project Partners (PPP) contracts

Executive summary

Purpose of Intervention

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 Division.  In accordance with this strategy, an inspection of SL’s Intelligent Customer capability for the 20-year Programme and Project Partners was carried out on 17, 18 & 26 November 2020.  The purpose of the inspection was to determine whether SL’s documented management arrangements meet the requirements of relevant statutory provisions and good practice.

Interventions Carried Out by ONR

A team comprising a Nuclear Safety Leadership & Management for Safety Inspector, Nuclear Safety Supply Chain Inspector, Nuclear Safety Quality Management Inspector and Nuclear Internal Hazards & Site Safety Inspector carried out the inspection.  The inspection focussed on the adequacy of the design elements of SL’s Intelligent Customer arrangements as applied specifically to the Programme and Project Partners. 

Due to the current COVID-19 (Coronavirus) pandemic restrictions, the intervention was undertaken remotely (utilising video conferencing) and followed a modular approach that has been successfully deployed in other recent ONR remote interventions.   

The inspection comprised a review of relevant documentation supplied by SL in advance of, and during, the inspection, with four modules spread over two days and a follow-up session approximately a week later.  Modules included structured discussions with SL staff and Lot Partners’ personnel.  ONR’s technical assessment guides NS‑TAST‑GD‑049: Licensee Core and Intelligent Customer Capabilities, Revision 7 (April 2019), NS-TAST-GD-057:  Design Safety Assurance, Revision 6 (November 2017) and NS- TAST-GD-079: Licensee Design Authority Capability, Revision 6 (June 2020) informed 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

The purpose of this inspection was to sample evidence of implementation of the Intelligent Customer capability for the Programme and Project Partners, in order to inform a regulatory judgement regarding the licensee’s compliance with relevant statutory provisions and good practice.  Given that I undertook the inspection remotely, I narrowed the scope to focus specifically on those aspects of the Intelligent Customer capability associated with Design and Design Safety Assurance and, where specific to a particular project, I targeted evidence associated with primarily the [Site Ion Exchange Effluent Plant] SIXEP Contingency Plant project.  In undertaking this inspection, there were several areas where I chose to rely on the assurances provided by SL.  Notwithstanding this, some limited sampling of evidence was undertaken, where possible, to support the inspection rating.

Specifically, this inspection focused on:

In terms of inspection findings, no significant matters were identified as requiring immediate regulatory attention.  Assurance was provided that SL understood the licensee’s corporate arrangements for acting as an Intelligent Customer for the Programme and Project Partners, and that SL and the Lot Partners understood their respective legal duties including those arising under Construction (Design and Management) Regulations 2015.  I tested some aspects of the underpinning evidence for the assurances received including, for example, examination of the e-mail approvals of training and competence records in lieu of ‘wet signatures’ on relevant documentation.

I examined a sample of the documented management arrangements covering the Intelligent Customer for the Programme and Project Partners.  These documents refer extensively to the term ‘Intelligent Client’.  I verified that the arrangements included specific requirements for the Intelligent Customer role.  These appeared to align well with published good practice as described in, for example, the relevant ONR Technical Assessment Guide (NS-TAST-GD-049).

I noted two particular areas of good practice in relation to Construction (Design and Management) Regulations 2015 arrangements, specifically, the use of a client brief and the approach to design reviews for the SIXEP Contingency Plant project.  I provided regulatory advice in relation to the greater consideration of “nuclear-specific” training for the non-Design Programme and Project Partners Aligned Delivery Team Lot Partner staff, the expansion of the proposed scope of the future planned Programme and Project Partners Nuclear Safety culture review to include Nuclear Security culture, the level of detail required on the Construction (Design and Management) Regulations 2015 F10 notification and the clarity of legal requirements in relation to appointments made under the regulations.  A number of other areas have also been identified that require further follow up and these will be considered as part of future routine regulatory interactions.

My findings were shared with, and acknowledged by, SL’s Intelligent Client for the Programme and Project Partners as part of normal inspection feedback.

Conclusion of Intervention

On the basis of the evidence sampled, I judge that, SL has adequately implemented the licensee’s corporate arrangements for acting as an Intelligent Customer for the Programme and Project Partners.  Noting the ONR guidance on inspection ratings, it is my opinion that an inspection rating of Green (no formal action) is merited here.  Some areas of good practice were highlighted. Some other areas were identified for follow up as part of future routine regulatory interactions.