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Sellafield - Inspection ID: 53283

Executive summary

Date(s) of inspection:

  • May 2024

Aim of inspection

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) Directorate. In accordance with this strategy a planned Corporate Licence Condition Inspection (CLCI), targeted at Sellafield Limited’s site-wide corporate arrangements for compliance with Licence Condition 24 (LC24) “Operating instructions” and their implementation, was undertaken 22-23 May 2024.

In addition to the inspection of Sellafield Limited’s site-wide LC24 arrangements and the site-wide implementation of these a specific additional aim of this inspection was to sample completed and planned Sellafield Limited LC24 improvement activities. This additional aim was selected because Sellafield Limited has regularly rated LC24 as Amber in its annual reviews of Licence Condition (LC) compliance and improvement activities submitted to the Sellafield Limited Nuclear Safety Committee. ONR therefore wished to gain confidence that earlier improvement activities had been delivered and that future improvement activities were well informed.

Subject(s) of inspection

  • LC24 - Operating instructions - Rating: Green

Key findings, inspector's opinions and reasons for judgement made

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) Directorate. In accordance with this strategy a planned Corporate Licence Condition Inspection (CLCI), targeted at Sellafield Limited’s site-wide corporate arrangements for compliance with Licence Condition 24 (LC24) “Operating instructions” and their implementation, was undertaken 22-23 May 2024.

In addition to the inspection of Sellafield Limited’s site-wide LC24 arrangements, and the site-wide implementation of these, a specific additional aim of this inspection was to sample completed and planned Sellafield Limited LC24 improvement activities. This additional aim was selected because Sellafield Limited has regularly rated LC24 as Amber in its annual reviews of Licence Condition (LC) compliance and improvement activities submitted to the Sellafield Limited Nuclear Safety Committee. ONR therefore wished to gain confidence that earlier improvement activities had been delivered and that future improvement activities were well informed.

This inspection was led by a Sellafield Corporate Site Inspector with support from a Leadership and Management for Safety (LMfS) Inspector and a Human Factors Inspector. 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.

This CLCI was the first undertaken since the Sellafield Enterprise Management System (SEMS) replaced the Sellafield Limited Management System (SLMS) in March 2024. Implementation of SEMS included establishment of a Compliance Requirement Owner (CRO) role accountable for making sure that compliance, against the requirements belonging to their compliance topic(s) is maintained at all times. One aspect of this is for the CRO to identify compliance requirements and map these to SEMS arrangements via a Compliance Matrix. During this inspection we identified some matters related to the LC24 Compliance Matrix which we considered would apply to the full SEMS LC Compliance Matrix and to the full SEMS Compliance Matrix. To allow these matters to be dealt with appropriately, our feedback includes a “Generic/ SEMS Matters” topic.

We consider that the engagement prior to and during this inspection has allowed us to complete a meaningful CLCI of LC24.

Feedback is recorded separately in relation to the following topics:

  1. The overall inspection;
  2. Licence Condition 24;
  3. Licence Condition 24 improvement priorities and planned activities; and,
  4. Generic/ SEMS Matters.

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

  1. Delivery of the information requested;
  2. Preparation for the inspection; and,
  3. Open, honest and helpful discussions and those persons involved were knowledgeable and receptive to challenge.

Licence Condition 24

On the basis of the evidence sampled before and during this inspection we identified the following observations as areas of good practice relating to Sellafield Limited’s LC24 arrangements and/ or their implementation:

  1. Opportunities offered by the SLMS to SEMS transition have been utilised;
  2. The SEMS CRO/ SEMS Process Owner responsible for LC24 was amongst the earliest to have been signed off as a Suitably Qualified and Experienced Person (SQEP) in these new nuclear baseline roles;
  3. Sellafield Limited has a clear understanding of the scope of LC24 operating instructions;
  4. Sellafield Limited has drafted guidance providing a graded approach to LC24 operating instructions retention periods;
  5. The process performance assurance plan activities relating to LC24 are well informed by multiple sources of intelligence and are clearly risk-based, with good links to relevant in the line performance assurance activities;
  6. Good intelligence relevant to LC24 is obtained by the identification and analysis of relevant Condition Reports;
  7. A good standard has been set for non-tolerance of overdue Category 1 LC24 operating instructions;
  8. Effective site-wide learning and improvement related to Procedure Use and Adherence (PUA) has been made in response to an earlier Enforcement Letter issued by ONR to one of the facilities on the Sellafield site; and,
  9. Good links have been set up between the LC24 team and the Safety Case team to support the key link between safety cases, the associated Licence Condition 23 (LC23) “Operating rules” and the associated LC24 operating instructions.

On the basis of the evidence sampled before and during this inspection we provided the following regulatory advice relating to Sellafield Limited’s LC24 arrangements and/ or their implementation. Sellafield Limited to consider:

  1. Providing guidance on the management of Temporary Instructions.

On the basis of the evidence sampled before and during this inspection we identified a regulatory finding relating to Sellafield Limited’s LC24 enterprise/ site-wide nuclear baseline for LC24. We raised a Level 4 (the lowest level) Regulatory Issue (RI) to monitor Sellafield Limited’s work to address this finding.

Licence Condition 24 Improvement Priorities and Planned Activities

During this inspection we satisfied ourselves that Sellafield Limited has developed and implemented an adequate assurance process relating to LC24 operating instructions.

Taking this and other evidence sampled before and during this inspection into account we are satisfied that:

  1. Sellafield Limited’s LC24 improvement priorities and planned activities for Financial Year (FY) 2023/2024 have been delivered and have led to significant improvements; and,
  2. LC24 planned improvements and activities for FY 2024/2025 are well supported by evidence and well founded.

Generic/ SEMS Matters

During this inspection we identified three generic/ SEMS matters. These were followed up during a subsequent inspection and have now been addressed.

Conclusion

On the basis of the evidence sampled before and during this inspection in relation to Sellafield Limited’s LC24 arrangements and/ or their implementation we identified:

  1. Nine areas of good practice;
  2. One item of regulatory advice; and,
  3. A single ONR finding which I have judged to represent a relatively minor deficiency.

Based on this, I considered that an Inspection Rating of Green (No Formal Action) for LC24 was appropriate, noting the relevant guidance within ONR documentation.

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