Sellafield - Inspection ID: 52643

The Office for Nuclear Regulation (ONR) undertakes all its regulatory interactions with the Sellafield site licensee, Sellafield Limited, against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. In accordance with this strategy, this was a planned Corporate Licence Condition Inspection (CLCI) of Licence Condition 14 (LC14) “Safety documentation”. It was targeted at Sellafield Limited’s Safety Case Process and Methods Improvement Plan.

The  Safety Case Process and Methods Improvement Plan was targeted for the following reasons:

a. To follow-up a comprehensive CLCI of LC14 in November 2021 which led to the Safety Case Process and Methods Improvement Plan being put in place which addressed Sellafield Limited’s self-identified shortfalls and the findings from the November 2021 inspection [which were included in several ONR Regulatory Issues (RIs) which are now Closed]; and,

b. To contribute to a wider ONR response to Sellafield being assigned a rating of Enhanced Regulatory Attention for the “Nuclear safety case adequacy and currency” supporting indicator within ONR’s framework for deciding on the regulatory attention (for safety) for licensed sites. [Information on regulatory attention is reported in the “Chief Nuclear Inspector’s annual report on Great Britain’s nuclear industry”].
 

This inspection was led by a Sellafield Corporate Site Inspector with support from a team of Inspectors specialist in the following areas: Fault Studies; Human Factors, Nuclear Liabilities Regulation (NLR); and, Radiological Protection and Criticality. Henceforth, the use of the pronoun “we” refers to this team whilst the pronoun “I” refers to the Sellafield Corporate Site Inspector. This inspection also utilised and supported Selllafield Limited’s internal challenge function via participation of a Sellafield Limited Nuclear Independent Oversight (NIO) Inspector.

We consider that the engagement prior to and during this inspection has allowed us to complete a meaningful CLCI of LC14 targeted at Sellafield Limited’s Safety Case Process and Methods Improvement Plan.

Several of the ONR specialist Inspectors reviewed selected Safety Case Guidance documents ahead of the inspection. The outcome of these reviews and associated discussions during the inspection were consolidated and reported to Sellafield Limited after this inspection.

Observations/ advice are recorded separately in relation to the following areas:

a. The overall inspection;

b. Licence Condition 14; and,

c. Nuclear safety case adequacy and currency regulatory attention indicator.

We identified the following observations as areas of good practice relating to delivery of the overall inspection:

a. Delivery of the information requested prior to and during this inspection;

b. Preparation for the inspection; and,

c. Open, honest and helpful discussions and those persons involved were knowledgeable and receptive to challenge.

The Safety Case Process and Methods Improvement Plan put in place to address a RI raised following the comprehensive CLCI of LC14 in November 2021 grouped shortfalls and findings into several categories. Based on these categories, key findings and judgements for this inspection are recorded for the following areas:

General

An observation of good practice was Human Factors matters being integrated into the Safety Case Process and Methods Improvement Plan where appropriate.

Safety Case Processes

Observations of good practice were:

a. The imminent end of the review of safety case processes, which represented good progress; and,

b. Establishment of a live “Index of Change” for each safety case process document and review of these periodically to decide when an update is needed.

Safety Case Guidance

Observations of good practice were:

a. Self-identification of the need for new guidance relating to the management phases of the safety case process; and,

b. Several observations identified during ONR’s reviews by ONR specialist Inspectors of selected Safety Case Guidance documents.

We provided regulatory advice to Sellafield Limited to consider:

a. Several items identified during ONR’s reviews by ONR specialist Inspectors of selected Safety Case Guidance documents; and,

b. Engaging supply chain support to avoid the Safety Case Guidance work being delayed by prioritising other work.

In relation to Safety Case Guidance, Sellafield Limited had self-identified that a large number of documents had not been reviewed and were old. We stated that this was a concern, as was the uncertainty over how or even if this guidance is used when developing safety cases.

We stated that having now almost updated the safety case processes, the line of sight between these documents and the Safety Case Guidance has largely been lost, limiting the use of this guidance to support implementation of the safety case processes. Sellafield Limited broadly concurred with these concerns.

We stated that although some work has been done to produce overview Safety Case Guidance documents, these have not been produced to a common standard and it is not clear how producing more of these documents would address the above concerns.

We identified the following regulatory finding relating to Sellafield Limited’s LC14 arrangements and/ or their implementation. Sellafield Limited to provide a framework, strategy and resource informed plan for Safety Case Guidance. 

A Level 4 (the lowest level) RI has been raised to monitor Sellafield Limited’s work to address this finding. Since completing the review and update of all the Safety Case Guidance will take multiple years the basis of closure of this RI will be Sellafield Limited:

a. Defines the desired “to be” Safety Case Guidance framework;

b. Provides its strategy for transitioning from the current “as is” Safety Case Guidance framework to the desired “to be” Safety Case Guidance framework, indicating how work will be prioritised to deliver early benefits.

c. Provides a resource informed plan to move from the current “as is” Safety Case Guidance framework to the desired “to be” Safety Case Guidance framework; and,

d. Sellafield Limited provides a small number of the early “to be” documents so that ONR can gain confidence in their quality and in progress against the resource informed plan.

We stated that once we are content that this RI is Closed, progress will then continue to be monitored as normal business via quarterly ONR/ Sellafield Limited safety case meetings.

Safety Case Assurance

Observations of good practice were:

a. Good progress has been made to fully fill the assurance gap self-identified before the November 2021 LC14 inspection; and,

b. The proposed 2024/2025 assurance plan is: in line with relevant Sellafield Limited management system guidance; is risk informed; and, provides clear line of sight to “Other Assurance” such as Condition Reports and intelligence back from in-the-line assurance etc.

Safety Case Capability

Observations of good practice were:

a. Good progress has been made implementing the 2021 “Safety Case Capability Strategy and Improvement Plan”; and,

b. Human Factors capability has been integrated into the existing safety case capability recruitment strategy.

We provided regulatory advice to Sellafield Limited to consider further use of embedded contractors in the nuclear baseline relating to safety case.

Despite good progress being made, Sellafield Limited recognises that there are challenges in several areas (including, in particular, Radiological Safety).

We recognise that safety case is not alone in facing resource challenges and a Level 3 RI is in place relating to enterprise-wide shortfalls in organisational capability.

The ONR owner of the Level 3 RI has been briefed on the relevant outcomes of this inspection.

Site Safety Case

We provided regulatory advice to Sellafield Limited to identify gaps between the current Sellafield Limited position related to “Site Safety Case” and what ONR considers to be relevant good practice.

Following a CLCI of LC14 in November 2021, Sellafield Limited put in place a Safety Case Process and Methods Improvement Plan. This was a multi-year improvement plan which included the following main areas:

a. Safety case processes;

b. Safety case guidance;

c. Safety case assurance;

d. Safety case capability; and,

e. Site safety case.

Based on this inspection we consider that the required improvements to:

a. Safety case processes have been adequately completed;

b. Safety case guidance is progressing adequately, whilst noting that further required improvements will take several years to complete;

c. Safety case assurance have been adequately completed; and,

d. Safety case capability is progressing adequately, whilst noting that improvements and challenges remain.

In addition, we are content that work to address site safety case has not started yet, given the required improvements which still need to be made to guidance and capability. We also accepted that the ongoing site-wide integrated risk-profiling work is likely to inform the way forward relating to this matter.

We are confident that the work completed so far and the work planned over the next few years has and will lead to improvements in nuclear safety case adequacy and currency.

On the basis of the evidence sampled before and during this inspection then in relation to Sellafield Limited’s LC14 arrangements and/ or their implementation we identified:

a. Nine areas of good practice;

b. Four items of regulatory advice; and,

c. A single ONR finding which I have judged to represent a relatively minor deficiency.

The single ONR finding relates to Safety Case Guidance. I have judged this finding to represent a relatively minor deficiency on the basis that Sellafield Limited has:

a. Self-identified most of the shortfalls related to Safety Case Guidance and is committed to address these shortfalls; and,

b. Already delivered a significant amount of work in its Safety Case Process and Methods Improvement Plan, which gives me confidence that the planned work to improve Safety Case Guidance will be delivered.

Based on this, I considered that an Inspection Rating of Green (No Formal Action) for LC14 was appropriate, noting the relevant guidance within ONR documentation.