- Site: Sellafield
- IR number: 21-013
- Date: May 2021
- LC numbers: 11
Executive summary
Purpose of Intervention
The Office for Nuclear Regulation (ONR) undertakes all its regulatory interactions with the Sellafield site licensee, Sellafield Limited (SL), against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. In accordance with this strategy, a planned inspection of Sellafield on-site emergency arrangements was carried out between 5-7 May 2021.
Clause 1 of Licence Condition 11 (LC11) “Emergency Arrangements” requires SL to “make and implement adequate arrangements for dealing with any accident or emergency on the site and their effects”. The main objective of this inspection is to assign a rating to SL’s site-wide corporate arrangements made to comply with LC11(1).
Additional objectives of this inspection are to:
- Gain assurance on SL’s site wide corporate arrangements made to comply with LC11(4), which relates to consultation;
- Gain assurance on SL’s site wide corporate arrangements made to comply with LC11(5), which relates to rehearsals;
- Gain assurance on SL’s site wide corporate arrangements made to comply with LC11(6), which relates to procedures;
- Gain assurance that the Sellafield on-site emergency arrangements meet the requirements of The Control of Major Accident Hazards Regulations 2015 (COMAH); and,
- Gain assurance that the Sellafield on-site emergency arrangements meet the requirements of The Radiation (Emergency Preparedness and Public Information) Regulations 2019 (REPPIR).
SL’s site-wide corporate arrangements made to comply with LC11(2) and LC11(3) were excluded from this inspection because a Level 4 (the lowest level) Regulatory Issue (RI) is already in place to address a shortfall relevant to these clauses, which relate to ONR primary powers.
The COMAH and REPPIR related objectives are included because, since the last inspection of this type (in 2014):
- Sellafield has become an upper tier establishment under COMAH; and,
- REPPIR and the associated Approved Code of Practice and guidance has replaced REPPIR 2001.
SL has rated itself against an Emergency Preparedness & Response (EP&R) Capability Map by use of a review it has undertaken which it refers to as an Emergency Management Capability Case (EMCC). Sampling of the evidence supporting SL’s EMCC and EP&R Capability Map ratings has formed a significant aspect of this inspection.
Interventions Carried Out by ONR
The inspection comprised discussions with SL staff and reviews of a targeted sample of SL’s documentation. The scope and priorities of the inspection took into account intelligence gained from other ONR interventions.
The inspections were carried out by a Nuclear Safety Inspector, with support from: the Sellafield Infrastructure Site Inspector; a Radiological Protection Inspector; a Nuclear Internal Hazards and Site Safety Inspector; and, a Nuclear Safety Project Inspector. A member of SL’s Nuclear Intelligence & Independent Oversight (NI&IO) function also participated.
Due to the ongoing Coronavirus (COVID-19) pandemic and the need to maintain social distancing, the inspection was run as a “hybrid” in which two members of the team participated on site whilst the remaining members of the team participated remotely.
Relevant ONR expectations used during this inspection included the following:
- ONR Nuclear Safety Technical Inspection Guide NS-INSP-GD-011 Issue 7.1, March 2021, “LC11 - On-site Emergency Arrangements”;
- COMAH and the associated guidance; and,
- REPPIR and the associated Approved Code of Practice and guidance.
Explanation of Judgement if Safety System Not Judged to be Adequate
Not applicable, as this was not a System Based Inspection.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
I (Nuclear Safety Inspector) consider that the engagement prior to and during the inspection has allowed a meaningful inspection of the Sellafield on-site emergency arrangements which met all the inspection objectives.
On the basis of the evidence sampled before and during this inspection, I identified three areas of good practice relating to the Sellafield on-site emergency arrangements, which are summarised as:
- SL has undertaken a comprehensive and self-critical review of its on-site emergency arrangements against the EP&R Capability Map outcomes;
- All SL personnel involved in the inspection demonstrated good knowledge of their roles and responsibilities; and,
- A good visual indication has been developed of relevant assurance.
I identified three areas of good practice relating to delivery of this inspection:
- Thorough preparation for the inspection and timely response to ONR information requests;
- Effective use of information technology to share information; and,
- The facilities and equipment enabled the “hybrid” on-site/ remote inspection to work well.
On the basis of the evidence sampled before and during this inspection, I identified four items of regulatory advice which all relate to future approval and implementation of the EMCC. The items of regulatory advice in summary relate to:
- NI&IO oversight of SL’s approval of the EMCC;
- NI&IO involvement during implementation of the EMCC, as required by SL’s arrangements, for higher safety categorisation modifications/ charges;
- NI&IO oversight of implementation of the EMCC for lower safety categorisation modifications/ changes; and,
- Sending the EMCC Summary Report to the SL Nuclear Safety Committee (NSC) for consideration and advice.
On the basis of the evidence sampled before and during this inspection, I identified a regulatory finding relating to records made to demonstrate compliance with LC11.
On the basis of the evidence sampled before and during this inspection, I identified three regulatory findings which I grouped into a theme “Emergency Management Capability Case”. The findings relate to SL’s arrangements to:
- Approve the EMCC and manage it going forward;
- Include the EMCC as part of SL’s LC11 arrangements; and,
- Implement the EMCC in line with SL’s arrangements for relevant LCs.
I consider that the shortfalls associated with the four regulatory findings are minor when considered individually or as a whole and I will monitor these shortfalls by raising two Level 4 (the lowest level) RIs.
The NI&IO participant was broadly content with the outcomes of this inspection.
Our regulatory advice and our regulatory findings were shared with, acknowledged and accepted by key SL staff involved in the inspection. SL was content with the outcomes of this inspection.
Conclusion of Intervention
Taking the above into account I consider that an inspection rating of Green (No Formal Action) is merited for SL’s LC11(1) arrangements, noting the relevant guidance within ONR documentation.
On the basis of the evidence sampled before and during this inspection, I gained assurance:
- Relating to SL’s site-wide corporate arrangements made to comply with LC11(4);
- Relating to SL’s site-wide corporate arrangements made to comply with LC11(5);
- Relating to SL’s site-wide corporate arrangements made to comply with LC11(6);
- That Sellafield on-site emergency arrangements meet the requirements of COMAH; and,
- That the Sellafield on-site emergency arrangements meet the requirements of REPPIR.