Executive summary
Date(s) of inspection:
June 2023Aim of inspection
Sellafield Limited’s extant Operators Emergency Plan (OEP) is Issue 20.
Due to prior ONR Specification (Licence Instrument (LI) 908), the OEP is an Approved arrangement in accordance with the expectations of Nuclear Site Licence Condition 11. To comply with the requirements of LC11(3), Sellafield Limited cannot alter or amend its OEP without prior Approval from ONR.
Issue 20 of the OEP was Approved by ONR via LI539. Sellafield Limited has recently requested ONR's Approval of Issue 21 of its OEP.
Implementation of Issue 21 of the OEP will enable Sellafield Limited to transfer the primary on-site Site Emergency Control Centre (SECC) into the Main Site Command Facility (MSCF) via a process that Sellafield Limited has referred to as ‘Command Transition’.
This Readiness Inspection was one component of a range of interventions that ONR carried out to gain assurance that the plant, people and processes at MSCF are in a suitable state of readiness to safely and securely complete the process of ‘Command Transition’ and thereby implement Issue 21 of the OEP.
These interventions align to an approved WIReD Permissioning plan and include – assessment of Issue 21 of the OEP and supporting arrangements, a Life Fire Safety Inspection of MSCF, observation of FridEx emergency exercises at MSCF, an observation of the Security and Resilience Management Safety Committee and multiple Level 4 discussions.
In respect of security, Sellafield Limited has a regulatory commitment under the Nuclear Industry Security Regulations 2003 to deliver an Initial Operating Capability at MSCF by March 2024. This primarily concerns the transfer of the Police Control Room functionality into the MSCF. Sellafield Limited indicated before this Inspection that Initial Operating Capability was expected to be delivered by February 2024.
An ONR Inspector of Nuclear Security participated in the Inspection, with a particular focus on; those aspects of Command Transition related to relocation of the Civil Nuclear Constabulary Operational Inspector into MSCF; ability of the Operational Inspector to communicate with the Police Control Room and Civil Nuclear Constabulary callsigns; the suitability of MSCF for storage of information classified “S” and; aspects of 'Command Transition' that addressed actions in pre-existing Regulatory Issues.
Subject(s) of inspection
- LC 11 - Emergency arrangements - Rating: GREEN
Key findings, inspector's opinions and reasons for judgement made
An approved WIReD Permissioning Record captures this Readiness Inspection as one component of a range of interventions that ONR carried out to gain assurance that the plant, people and processes at the Main Site Command Facility (MSCF) were in a suitable state of readiness to safely and securely complete the process of ‘Command Transition’ thereby making MSCF the primary Site Emergency Control Centre (SECC) at Sellafield, implementing Issue 21 of Sellafield Limited's Operator Emergency Plan (OEP).The inspection team comprised of an ONR Nuclear Safety Inspector with responsibility for ONR's permissioning of Issue 21 of the Sellafield Limited OEP, a Human Factors Specialist Inspector and an ONR Inspector of Nuclear Security due to security matters at MSCF related to compliance with the Nuclear Industries Security Regulations 2003.
Sellafield Limited provided sufficient evidence to enable this intervention to be a meaningful inspection.
ONR identified some areas of good practice relating to; delivery of the inspection; Sellafield Limited's application of independent challenge; implementation of arrangements for LC11, and; elements of Sellafield Limited’s preparations for 'Command Transition'.
I considered that during the course of this Inspection, supplemented by additional evidence shared with ONR after the Security and Resilience Management Safety Committee held on 29th June 2023, Sellafield Limited provided an adequate demonstration that the plant, people and processes at MSCF had attained a sufficient level of readiness for ONR to grant Approval of Version 21 of the Sellafield Limited OEP thereby enabling 'Command Transition' to be implemented.
I considered that an Inspection rating of Green (No Formal Action) for LC11 was appropriate, since no significant shortfalls against ONR's regulatory expectations for LC11 were identified.
I gained assurance that Sellafield Limited was responding appropriately to all pre-existing Regulatory Issues relevant to the people, plant and processes at MSCF and that the proposed position for 'Command Transition' was compatible with successful resolution of those Regulatory Issues.I also identified some areas for improvement, against which ONR provided regulatory advice and guidance and I have raised one new Level 4 (lowest level) Regulatory Issue.
Some technical challenges remain at MSCF, which currently restrict the facility's level of resilience. These residual matters are acknowledged by Sellafield Limited, with plans in place to secure a range of improvements before the building's next key milestone of 'Initial Operating Capability'.
I therefore judged Sellafield Limited's current position to be sufficient for the purposes of 'Command Transition', but further work is needed before MSCF can be operated in accordance with its design intent and fully deliver the best practices of the Joint Emergency Services Interoperability Principles.
ONR identified the following regulatory finding:
Operability of the MSCF Air Handling Units
This finding inhibits the adoption of a 'stay put' policy for the MSCF Operations Floor, reducing the facility's level of resilience against credible scenarios. Having considered this finding I have raised one Level 4 Regulatory Issue:
Operability of the MSCF Air Handling Units
Full details of the areas of good practice, regulatory advice and regulatory findings are in the WIReD Intervention Record which is shared with Sellafield Limited.
Sellafield Limited personnel present at the hot debrief were in broad agreement with the outcomes of the Inspection.
Conclusion
Two separate judgements were made:- Rating for LC11, and;
- Decision on whether the people, plant and processes at MSCF had attained a sufficient state of readiness to allow ONR to grant Approval for Issue 21 of the Sellafield Limited Operator Emergency Plan.
One Level 4 Regulatory Issue was raised to monitor Sellafield Limited’s redress of a regulatory finding arising from this inspection:
Operability of the MSCF Air Handling Units
Rating for LC11
Residual matters relating to operability of the Air Handling Units and Life Fire Safety provisions currently prevent adoption of the intended 'stay put' policy for the MSCF Operations Floor, which reduces the facility's level of resilience against credible scenarios.
However a mitigative policy of 'swift evacuation', combined with the opportunity for staff to relocate from MSCF to either the pre-existing Site Emergency Control Centre (SECC) elsewhere on site, or to the Off Site Command Facility, provides protection of personnel whilst allowing an adequate emergency response capability to be maintained and is equivalent to the current arrangements at the pre-existing SECC.
Sellafield Limited provided satisfactory evidence that the actions relating to MSCF found within the Emergency Management Capability Case Implementation Plan had been adequately addressed.
I therefore considered that an Inspection Rating of Green (No Formal Action) for LC11 was appropriate, since no significant shortfalls against the regulatory expectations for LC11 were identified.
Decision to Recommend Approval of Issue 21 of the Sellafield Limited Operator Emergency Plan
I considered that during the course of this inspection, supplemented by the additional evidence ONR was provided after the Security and Resilience Management Safety Committee held on 29th June 2023, Sellafield Limited gave an adequate demonstration that the plant, people and processes at MSCF had attained a sufficient level of readiness to safely and securely implement the process of 'Command Transition' thereby allowing ONR to grant Approval of Issue 21 of the Sellafield Limited OEP.
The nature of the gaps to relevant good practice that currently exist at MSCF are not such that the facility is unsafe or inoperable. Sellafield Limited has openly acknowledged the presence of shortfalls in respect of operability of the Air Handling Units and provisions for Life Fire Safety and adopted an adequately mitigated position. The overall capability of MSCF to provide an emergency response is at least equal to that of the pre-existing SECC.
Further work is required before MSCF can be operated in accordance with its design intent and thereby deliver the full scope of intended resilience. On the basis of Sellafield Limited's extant plans, these residual matters should be resolved prior to attainment of 'Initial Operating Capability' the target date for which is February 2024.