- Site: Sellafield
- IR number: 21-102
- Date: October 2021
- 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 Highly Active Liquor Evaporation and Storage (HALES) and High Level Waste Plants (HLWP) facilities have adequately implemented Sellafield Limited’s site-wide arrangements and local specific arrangements for compliance with Licence Condition (LC) 11 (Emergency arrangements).
Due to the current coronavirus (COVID-19) pandemic, the intervention followed a blended approach involving a mixture of remote engagement supplemented by an on-site inspection by the ONR Project Inspector. The inspection has been carried out in line with the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division’s regulatory approach to the COVID-19 pandemic.
This inspection is complementary to ONR’s inspection of Sellafield Limited’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 Sellafield Limited staff, examination of plant documentation and inspection of facilities and equipment. It focussed on the following areas:
- HALES and HLWP implementation of Sellafield’s LC11 arrangements, including the implications of applicable arrangements’ variations.
- 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 HALES and HLWP, including on plant inspection element of Access Control Point (ACP) and the Incident Control Centre (ICC).
- The ability and effectiveness of the HALES and HLWP 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
During the inspection, I saw evidence that the Emergency Duty Team members on duty were SQEP for their emergency roles. During the plant walkdown in HALES and HLWP, I saw evidence that the Incident Control Centre (ICC) was appropriately set up and stocked. When visiting an Access Control Point (ACP), I identified one minor shortfall in relation to emergency equipment condition within and I gave regulatory advice to create an ACP inventory to ensure that equipment is maintained in good working condition. Based upon sampling of submitted documents, discussions with Sellafield Limited staff and a facility walk-down, I judged that HALES and HLWP has complied with requirements of the LC 11 arrangements in place.
In response to the COVID-19 pandemic, Sellafield Limited has developed variations to its corporate LC 11 arrangements in order to introduce some flexibility but in a way which still maintains compliance with legal obligations. Prior to this intervention, I reviewed the two valid and relevant variations: for the topic area of emergency management and for the topic area on training. In this inspection I found that HALES and HLWP had applied the LC 11 variation in an appropriate way.
Notwithstanding the minor shortfall identified above, it is my opinion that the licensee has adequately implemented its arrangements for compliance with LC 11. The staff interviewed had good knowledge of the extant arrangements and provided some satisfactory supporting evidence. The compliance with the requirement for minimum manning safety levels provides sufficient emergency staffing levels.
Conclusion of Intervention
On the basis of the evidence gathered during the inspections, I judge that an inspection rating of GREEN (No Formal Action) is appropriate for compliance against LC 11 given that Sellafield Limited has adequately implemented its corporate arrangements for this LC.