Executive summary
Date(s) of inspection:
- March 2025
Aim of inspection
The purpose of this inspection is to sample evidence of implementation of the Sellafield Limited arrangements for compliance with Licence Conditions (LC)10 (Training), LC11 (Emergency arrangements) and 36 (Organisational capability), primarily in relation to emergency response arrangements, specifically at FGMSP, in order to inform a regulatory judgement regarding the licensee’s compliance with its legal duties under the nuclear site licence.
Subject(s) of inspection
- LC10 - Training - Rating: Green
- LC11 - Emergency arrangements - Rating: Green
- LC36 - Organisational capability - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
In accordance with the Office for Nuclear Regulation’s (ONR’s) Sellafield Strategy, each year ONR performs a series of inspections of Sellafield’s systems. The purpose of this intervention is to check compliance of Licence Conditions (LC)10 (Training), LC11 (Emergency arrangements) and 36 (Organisational capability) with a focus on emergency arrangements at First Generation Magnox Storage Pond (FGMSP).
The LC36 inspection undertaken at FGMSP in October 2023 was rated amber. This was based on the lack of clear operating plan within FGMSP at the time of the inspection and the routine failure to meet Minimum Safety Manning Levels (MSML). The inspection also observed challenges around resourcing across the facility noting it was part way through a recovery plan and transitioning to the Target Operating Model (TOM).
ONR noted that there is still an open enforcement letter which was issued following the fourth delayed KDM M14, relating to compliance shortfalls against MHSWR 1999, Reg 5 - effective planning, organisation, control, monitoring and review of the preventive and protective measures.
I inspected LC10 (Training), primarily in relation to emergency response, and was satisfied that, despite the transfer of experienced people from the Control Room, FGMSP are aware of the training requirements and have flexibility to provide cover where necessary. I was satisfied that the status of training is kept under review at the Training Advisory Committee meetings.
I inspected LC11 (Emergency Response) and found that FGMSP were able to describe the gaps in training and SQEP amongst their responders, I was satisfied that the DAP was actively managing the deployment of resource to satisfy MSML requirements and noted the improving trends relating to MSML initiating event reports.
I inspected LC36 (Organisational Capability), and was satisfied that there has been a reduction in the number of MSML challenges, and, despite some nuclear baseline gaps remaining, capability within FGMSP has improved. I provided regulatory advice where I observed some minor deviations from the Sellafield Ltd arrangements.
I do not consider that these shortfalls require formal regulatory action, and I have instead provided regulatory advice to Sellafield Ltd. Consequently, and in accordance with ONR’s arrangements, I consider a rating of Green (no formal action) appropriate for each Licence Condition covered in this inspection.
Overall, I found that Sellafield Ltd is complying with the key requirements of LC10, 11 and 36, albeit with some minor areas of non-compliance.
Conclusion
The inspection commenced with a presentation on the background to the facility, the organisational structure, shift patterns and change in staff numbers during late 2022 as a result of staff redeployment. In 2023, a new lead team for Legacy Ponds was introduced who developed a MoCRA for a new Target Operating Model (TOM) which was implemented in summer 2024. The choice of the structure of the TOM was facilitated through a workshop, but a discussion was held on whether there was sufficient opportunity for operator/safety rep input and influence of the chosen model.
A discussion was held on control room operator/task training, and what is required to keep the plant safe during an emergency event. The inspectors reached a conclusion that the facility was compliant with the SL arrangements.
ONR provided some advice on the MSML paper, primarily in relation to ensuring the golden thread is consistent with the overarching Retrievals MSML paper.
A discussion was held on MSMLs, and the definition of mitigated and unmitigated challenges. Overall, I was satisfied to see the improvement in the reduced number of MSML challenges from October 2024 which has been driven by an increased number of SQEP operators.
Based on the information provided during the inspection, I am satisfied that the current level of vacancies within FGMSP Operations and E&M are being managed adequately.
I was satisfied that FGMSP are adequately managing the nuclear baseline, and maintaining oversight of any vulnerabilities.
ONR observed a good practice in relation to the Leader in the Field activities being undertaken at FGMSP. The initiative appeared to be having a positive impact on staff. Sellafield confirmed the use of in-line assurance functions and the use of leading indicators.
ONR noted that there appeared to be positive observations in relation to the broader team dynamic at the facility, specifically in relation to honest, transparent and open discussions held between all stakeholders, both internal and external to Sellafield.
ONR reiterated the importance of a positive safety culture, even more so given the national significance of FGMSP and High Hazard Risk Reduction work being undertaken.
ONR judged that Sellafield Limited has adequately implemented the relevant claims in the safety case and that the formal arrangements for LCs 10, 11 and 36 are being adequately implemented for FGMSP sludge retrievals.
Overall, ONR judged that the safety system is adequate and fulfils the requirements of the safety case.
In accordance with ONR’s arrangements, I consider a rating of Green (no formal action) appropriate for this inspection.