The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with Sellafield Limited (SL, the site licensee) against a strategy defined by ONR’s Sellafield Programme. The planned inspection schedule for the current regulatory year (covering April 2015 – March 2016), the content of which is guided by that strategy, defines those Licence Conditions (LC) that will be inspected over this period within SL’s Infrastructure division.
This intervention was undertaken to determine if the site is implementing adequately its site-wide arrangements for compliance with Licence Condition 11 (Emergency Arrangements). This intervention fulfils the requirement set by ONR for SL to demonstrate the site’s emergency management performance on at least an annual basis.
Licence Condition 11 (LC11) requires the licensee to make and implement adequate arrangements to deal with any accident or emergency arising on the site.
Our inspection, which comprised an assessment of a site-wide emergency exercise that was planned and managed by the licensee, was completed in accordance with the following ONR guidance:
The exercise scenario included (fictional) dropped load and loss of containment events in the site’s Separation Area, and necessitated practising SL’s management of contaminated personnel and casualty-handling. The scenario also rehearsed a number of novel aspects such as out-of-hours working (so the emergency team needed to be called-in from off-site) and the use of the site’s standby emergency response centre.
The exercise was assessed by a multi-disciplined team of eight inspectors located at key positions around the site plus two observers from ONR (for experience development purposes).
Not applicable; this was not a Safety System inspection.
SL demonstrated an adequate emergency response performance in this exercise. This included a particularly strong performance from SL’s Incident Control Centre (ICC) in the Separation Area and a good performance from the Site Emergency Control Centre (SECC) given the acknowledged additional challenges of working in the standby centre and SL’s choice of an out-of-hours scenario. As such ONR awarded the exercise a Pass rating, i.e. we consider SL would have coped adequately had this been a real event.
However, we also noted a number of deficiencies in SL’s provision of health physics advice, support and control of potential contamination. These included shortfalls in the conservative management of emergency dose limits, in ensuring radiation risks to staff are managed to as low as reasonably practicable in the circumstances and in adopting relevant good practice to limit the spread of potential contamination from returning emergency response teams.
Although most aspects of SL’s emergency response demonstration were adequate, I have awarded an IIS rating of 4 (below standard) in view of the shortfalls we observed in the health physics area.
We shared our observations with SL at a Hot Debrief session held the day following the exercise. We welcomed the strong degree of alignment between ONR’s observations and those of SL’s own emergency exercise reviewers.
Importantly, SL had also noted deficiencies in its health physics response and, prior to the exercise, had already initiated an improvement programme. In view of our findings here, I have raised an ONR Regulatory Issue to manage health physics improvements in emergency response. ONR’s management of this Issue will include monitoring SL’s existing improvement programme.
ONR’s wider observations will be shared with the licensee at a later date as part of normal regulatory business.