Office for Nuclear Regulation

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Planned interventions with LLWR relating to LLWR site operations undertaken as part of the planned ONR programme covered by the ONR LLWR inspection plan for 2015/16

Executive summary

Purpose of intervention

This report covers a number of interventions with the Low Level Waste Repository (LLWR), relating to LLWR operations which were undertaken as part of the planned ONR LLWR inspection programme for 2015/16

Interventions Carried Out by ONR

The main interventions undertaken during the site visit were:

During the visit a number of other interventions/discussions were undertaken including:

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable

Key Findings, Inspector's Opinions and Reasons for Judgements Made

Site Licence Condition 6 Inspection & Discussions This inspection was focussed on Licence Condition 6 (LC6) “Documents, records, authorities and certificates” but also covered aspects of the LLWR arrangements for LC25 “Operational records”. Overall the ONR Site Inspector considered the arrangements were adequate and no significant issues were raised from the inspection although some areas for improvement are recognised by LLWR. The ONR Site Inspector will follow up on the ongoing LLWR work in this area during future site interventions.    

LLWR Emergency Exercise “Theta 9” – The ONR Site Inspector witnessed the LLWR Emergency exercise “Theta 9” at the “incident scene”. The ONR Site Inspector sought to observe a number of aspects of the LLWR response which were not considered to have been adequately demonstrated (due to “exercise scenario management” problems) during the ONR observed Level 1 Demonstration Exercise “Theta 8” in June. The ONR Site Inspector considered that this exercise did allow LLWR to demonstrate their capabilities in those areas affected by the problems that occurred during the “Theta 8” Demonstration Exercise. The ONR Inspector observed some areas of good practise however a number a number of areas of improvement were noted relating to setting up of/contamination control at the Forward Access Control Point, the handling of the casualty and the debriefing of the event witnesses.  The ONR Site Inspector comments will be followed up with LLWR during the next site visit when the LLWR report covering all areas of the exercise will have been issued.  

Site Licence Condition 22 follow up Inspection – A follow up inspection was undertaken to the Licence Condition 22 (LC22) “Modification or Experiment on existing plant” inspection carried out in January 2015. This inspection focussed on the work undertaken by LLWR to address the issues raised during the original inspection eg “Overdue” Plant Modification Proposals (PMPs)/Target completion date (TCD) management, numbers of Open/Overdue PMPs, PMP closure arrangements, PMP amendment procedures, arrangements/guidance on when an “Overarching” PMP (OSP) are required/beneficial, categorisation of PMP and “Fast Track” process for approval for urgent PMPs. Overall, the ONR Site Inspector considered that LLWR had made significant progress in addressing the issues raised during the initial inspection and had been proactive and positive in planning and implementing work programmes in this area. It is planned that further inspections which will be programmed into the ONR 2016/17 LLWR Inspection Plan to follow up the progress made by LLWR

LLWR Emergency Arrangements Capability Map Matrix Discussions - A meeting was arranged to undertake an initial review of the LLWR Emergency Arrangements Capability Map Matrix. All licensees have been required to respond to the question set on the Capability Map Matrix pro-forma and then have their response assessed by ONR. This meeting reviewed a draft version of the LLWR “map”. Overall ONR considered that LLWR had compiled an adequate response but ONR indicated that certain aspects required to be supplemented including areas relating to security arrangements. It was agreed that LLWR would revise their Capability Map by the end of November.     

Other interventions - It is considered that the various interventions undertaken did not raise any significant new issues or concerns. However a number of actions were placed on LLWR to progress and several topics will be followed up in future site visits/ discussions with LLWR staff.

Conclusion of Intervention

Other than the items outlined in the previous section no other matters were raised during the interventions covered by this report which were considered to require any immediate additional regulatory action.