Executive summary
Date(s) of inspection:
October 2024
Aim of inspection
The aim of the inspection is to ensure that Sellafield Ltd’s (SL) supply chain management arrangements, particularly those implemented within its Operational Technology Group (OTG), are adequately controlling risks from Counterfeit, Fraudulent and Suspect Items (CFSI) in line with regulatory requirements. Further to that, to ensure there is adequate understanding and implementation of the required CFSI arrangements within Sellafield Ltd.’s wider supply chain.
The inspection will sample the Sellafield Ltd response to ONR alert note on CFSI dated 7 December 2022, and the planned CFSI management improvement and actions taken as a result of Regulatory Issue 11417 following shortfalls found in the implementation of Sellafield Ltd.'s arrangements for the procurement of operational technology and information technology, and use of “at risk” procurement routes*, identified in 2023.
The inspection will consider the requirements of Licence Condition (LC) 17 (1 and 2) Management Systems which requires the licensee to establish and implement management systems which give due priority to safety and within its management system, to make and implement adequate quality management arrangements in respect of all matters which may affect safety.
The inspection will also consider the requirements of Licence Condition 6 (1 and 2) – documents, records, authorities and certificates which requires the licensee to make adequate records to demonstrate compliance with any conditions attached to their licence and to make and implement adequate arrangements to ensure that every document required, every record made, every authority, consent or approval granted and every direction or certificate issued in pursuance of the conditions attached to this licence is preserved for 30 years or such other periods as ONR may approve.
Subject(s) of inspection
- LC6 - Documents, records, authorities and certificates - Rating: Green
- LC17 - Management systems - Rating: Amber
Key findings, inspector's opinions and reasons for judgement made
The purpose of this inspection was to seek assurance that Sellafield Ltd.’s (SL) supply chain management arrangements, within its Operational Technology Group (OTG), were adequately controlling risks from Counterfeit, Fraudulent and Suspect Items (CFSI) in line with relevant good practice and regulatory expectations. This was to inform regulatory judgement regarding licensees compliance with relevant statutory provisions and good practice.
The inspection sampled CFSI management improvement and actions taken as a result of Regulatory Issue 11417 following shortfalls found in the implementation of Sellafield Ltd.'s arrangements for the procurement of operational technology and information technology and use of “at risk” procurement routes, identified in 2023.
The inspection revealed OTG remain in a period of transition regarding its CFSI arrangements and knowledge of Sellafield Ltd. quality arrangements, but are committed to work towards alignment with wider Enterprise arrangements.
I identified that relevant good practice was met in part, however there were some shortfalls identified when compared with appropriate benchmarks, these related to:
- No clear governance around the production and use of local OTG guidance and alternative procurement routes outside of Sellafield’s management system arrangements,
- lack of evidence of risk based enhanced testing methods for suspect items and at-risk procurement routes,
- lack of evidence of a risk based approach which adequately considers quality grade (QG),
- awareness and capability within OTG around Sellafield Ltd.’s management system arrangements for procurement and quality,
- continued use of lower tier grey market suppliers without demonstration of adequate intelligent customer oversight and assurance, and
- environmental conditions for storage of control and instrumentation items to prevent degradation.
Conclusion
I concluded there were significant shortfalls related to Licence Condition 17 (management systems) which I have rated amber. The shortfalls against Licence Condition 6 (records) are more minor in nature resulting in a green rating against this licence condition. Considering all the evidence I have concluded that an overall inspection rating of Amber, seek improvement, is appropriate.
I considered that there were shortfalls against identified relevant good practice when compared to appropriate benchmarks such as IAEA Nuclear Energy Series No. NP-T-3.26 - Managing Counterfeit and Fraudulent items in the Nuclear Industry.
During the inspection feedback meeting I outlined my intention to raise appropriate regulatory issues to capture the identified shortfalls and to monitor Sellafield Ltd progress in making improvements. I provided regulatory advice and guidance relating to identified areas for improvement for Sellafield Ltd to consider, these will be followed up via routine engagements.
Sellafield Ltd. agreed with my findings, the overall inspection rating and considered the feedback I provided was balanced.