Office for Nuclear Regulation

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LC11 and LC32 Inspection BTC NNL laboratories

Executive summary

Purpose of intervention

The Office for Nuclear Regulation (ONR) undertakes all regulatory interactions with Sellafield Limited (SL, the site licensee) against a strategy defined by the ONR Sellafield Programme.  My planned inspection schedule for the current regulatory year (covering April 2015 – March 2016), the content of which is guided by that strategy, identifies the Licence Conditions (LCs) that will be inspected over this period. 

This intervention was undertaken to determine if the National Nuclear Laboratory’s (NNL) Central Laboratory, (termed the BTC, British Technology Centre), is adequately implementing SL’s site-wide arrangements for compliance with Licence Conditions 11 and 32.  This facility was selected for inspection since it contains a significant inventory of nuclear and radioactive material, and the quantity of such material and associated scope of operations is likely to grow in the future, as more of the facility undergoes active commissioning. It is also proposed that analytical services for the Sellafield site may transfer from another facility to the BTC in the future. It should be noted that although the facility is on the licensed site, and hence duties under the licence conditions rest with SL, the facility is operated by NNL as a tenant.

Interventions Carried Out by ONR

Licence Condition 11 (LC11) requires the licensee to make and implement adequate arrangements for dealing with any accident or emergency arising on the site and their effects.

 My inspection, which comprised discussions with SL and NNL staff, and examination of plant documentation, and observation of a building emergency exercise, focussed on the following areas:

Licence Condition 32 (LC32) requires the licensee to make and implement adequate arrangements for minimising, so far as is reasonably practicable, the rate of production and total quantity of radioactive waste accumulated on the site at any time and for recording the waste so accumulated.

My inspection, which comprised discussions with SL and NNL staff, examination of plant documentation, and physical inspection of the facility, focussed on the following areas:

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable; this was not a Safety System inspection.

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

I consider that SL’s arrangements for compliance with LC 11 have been effectively implemented at the BTC.  There were a number of areas of good practice, and a number of minor improvements that could reasonably be made, all of which were accepted by the dutyholders.  For instance there was evidence of good planning of exercises throughout the year, and effective rostering of staff. The Emergency Preparedness & Response (EP&R) facilities within the building were of a good standard, and the demonstration / training exercise observed during the day was also delivered well. These are however offset by minor shortcomings in terms of the reliance on a single resource in the EP&R planning and management function, and the vulnerability of associated information which is held on a local computer drive.

 For these reasons, I consider an IIS rating of 3 (Adequate) is merited against LC11 as a result of this inspection.

I consider that SL’s arrangements for compliance with LC 32 have been effectively implemented at the BTC.  There were a number of areas of good practice, and a number of minor improvements that could reasonably be made, all of which were accepted by the dutyholders. For instance the facility has appointed appropriate waste coordinators who displayed a good knowledge of their subject area, and generally good processes were in evidence within the facility. These are however offset by a few minor shortcomings which were recognised by the facility and licensee. Specifically the facility should expedite the processing of Low Level Waste (LLW) presently stored within the facility, where a backlog has developed. 

For these reasons, I consider an IIS rating of 3 (Adequate) is merited against LC32 as a result of this inspection.

Conclusion of Intervention

My findings were shared with, and accepted by, the dutyholders as part of normal inspection feedback. No ONR Regulatory Issues were raised as a result of this inspection.