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Compliance inspection of Licence Condition 11 (Emergency arrangements)

  • Site: Sellafield
  • IR number: 21-158
  • Date: January 2022
  • 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 Engineered Drum Stores (EDS) and Waste Treatment Complex (WTC) facilities within Remediation Value Stream have adequately implemented Sellafield Limited’s 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 Sellafield Limited’s implementation of arrangements for compliance with the aforementioned Licence Condition, to test the resilience of these arrangements and Sellafield Limited’s ability to respond if significantly challenged by the pandemic, thus demonstrating the extent to which Sellafield Limited is compliant with their arrangements. 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 LC11 (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:

  • The Remediation value stream implementation of Sellafield’s Limited 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 EDS and WTC facilities at Remediation Value Stream.
  • The ability and effectiveness of the Remediation 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 my opinion that the licensee has adequately implemented its arrangements for compliance with LC11. It is considered that EDS and WTC facilities’ implementation of the site’s arrangements for LC11 is adequate. The staff interviewed had a good knowledge of the extant arrangements and provided satisfactorily supporting evidence. The use of cross value stream resource provides sufficient emergency staffing levels and equipment coverage.

During the inspection, we saw evidence that the Emergency Duty Team members on duty were Suitably Qualified Experienced Personal (SQEP) for their emergency roles. During the plant walkdown in the EDS and WTC, we saw evidence that the mobile Access Control Points (ACP)s were appropriately set up and stocked. When visiting an ACP, we identified a minor shortfall, in relation to completion of an emergency equipment inventory check, that was promptly rectified by the plant.

 While reviewing an emergency management improvement programme, we identified an outstanding improvement action, tracking a review of WTC’s criticality alarm effectiveness in some plant areas. We have raised a regulatory issue Level 4 (minor) to gain confidence in prompt completion of this improvement.

Based upon sampling of submitted documents, discussions with Sellafield Limited staff and a facility walk-down and notwithstanding the minor shortfall identified above, we judged that the EDS and WTC have complied with the requirements of the LC11 arrangements in place.

Conclusion of Intervention

The inspection concluded that the licensee had adequately implemented its arrangements for LC11 at EDS and WTC. We therefore consider, noting the ONR guidance on inspection ratings, that an inspection rating of Green (no formal action required) is merited here. A Level 4 Regulatory Issue (RI-10581) is raised for an oversight of completion of an identified shortfall in relation to criticality alarm effectiveness.