- Site: Sellafield
- IR number: 20-071
- Date: December 2020
- LC numbers: 11
Executive summary
Purpose of Intervention
In accordance with the Office for Nuclear Regulation’s (ONR’s) Sellafield Strategy, each year ONR performs a series of planned compliance inspections of selected licence conditions, targeted at those facilities with significant importance to nuclear safety.
This record describes the outcome from the planned intervention undertaken to determine if the Retrievals Value Stream has adequately implemented Sellafield Limited’s (SL) site-wide arrangements and local specific arrangements for compliance with Licence Condition (LC) 11 (Emergency arrangements).
In light of the Covid-19 Pandemic the purpose of this inspection was to sample evidence of SL implementation of arrangements for compliance with the aforementioned Licence Condition, to test the resilience of these arrangements and SL’s ability to respond if significantly challenged by the pandemic, thus demonstrating the extent to which SL is compliant with their arrangements.
In response to the pandemic, SL has recognised that its existing corporate compliance arrangements should remain unchanged and continue to be complied with where possible. Nonetheless, as a contingency, SL has developed variations to some of its corporate arrangements in order to introduce some flexibility, but in a way which still maintains compliance with legal obligations. SL has put in place variations to its corporate arrangements which affect its arrangements for compliance with LC 11. Prior to this intervention, ONR has reviewed the relevant variations and is satisfied that they are adequate. This inspection has included consideration of whether the variations have been used at the Retrievals Value Stream, and if so, whether they have been complied with.
This inspection is complementary to ONR’s inspection of SL’s site wide demonstration of compliance with LC 11 (Emergency arrangements).
Interventions Carried Out by ONR
Licence Condition 11 requires the licensee to make and implement adequate arrangements for dealing with any accident or emergency arising on the site and their effects.
The inspection comprised discussions with SL staff, examination of plant documentation and inspection of facilities and equipment. It focussed on the following areas:
- The Retrievals Value Stream implementation of SL’s LC11 arrangements.
- Evidence regarding the planning and conduct of training exercises on emergency management.
- Evidence regarding the training and competence of personnel associated with LC11.
- The adequacy of facilities and equipment to support emergency management within the Retrievals Value Stream.
- The resilience of the organisation to a significant impairment to its response capability due to the Covid-19 pandemic.
- The ability and effectiveness of the Retrievals Value Stream to apply learning from experience during and after the period of pandemic response.
Explanation of Judgement if Safety System Not Judged to be Adequate
This was not a system based inspection, and therefore no judgement has been made of the adequacy of implementation of any part of the safety case.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
It is ONR’s opinion that the licensee has adequately implemented its arrangements for compliance with LC 11. It is considered the Retrievals Value Stream’s implementation of the site’s arrangements for LC 11 is adequate. The staff interviewed had a good knowledge of the extant arrangements and provided some satisfactorily supporting evidence. The use of cross Retrievals resources provides sufficient emergency staffing levels and equipment coverage.
In relation to social distancing measures, ONR found the measures implemented by the Retrievals Value stream, were robust and the facility were always striving to improve them, it was noted that the plant personnel developed the arrangements to ensure operations could continue with minimal disruption.
Conclusion of Intervention
The inspection concluded that the licensee had adequately implemented its arrangements for Licence Condition 11. ONR therefore consider, noting the ONR guidance on inspection ratings, that an inspection rating of Green (no formal action required) is merited here for the Retrievals Value Stream on the Sellafield Site.