This intervention was undertaken on 9 and 12 November 2015 at Sellafield Limited’s (SL) Sellafield nuclear licensed site in Cumbria, and focussed on the Magnox Reprocessing Separation Plant (MRSP).
Inspection of Licence Condition (LC) compliance at nuclear licensed sites forms a significant part of ONR’s activities. ONR’s Sellafield Programme has defined a programme of system inspections and LC compliance inspections to be undertaken on the Sellafield site, this is a key aspect of ONR’s regulatory strategy (for the Sellafield site). Undertaking this intervention is consistent with this strategy, and is identified on ONR’s project delivery inspection plan which covers Sellafield Limited’s MRSP. The MRSP was selected for this intervention because there are significant on and off-site consequences arising from certain fault scenarios identified in the plant safety case.
LC11 ‘Emergency Arrangements’ requires the licensee to make and implement adequate arrangements for dealing with any accident or emergency arising on the site and their effects.
I completed a LC11 compliance inspection in accordance with the following ONR guidance:
I undertook the inspection over two half days, discussing the emergency arrangements with a number of SL staff and undertaking a plant walk down.
N/A. This was not a safety system inspection.
SL have identified all reasonably foreseeable scenarios that may lead to an accident or emergency situation in Magnox Reprocessing against plant faults identified in the safety case, risk assessments and identified areas of improvement from previous exercises or incidents. I am satisfied that the extant MRSP emergency arrangements include the reasonably foreseeable accidents and emergencies that have been identified.
There is a dedicated Emergency Preparedness & Response (EP&R) capability within Magnox Reprocessing, and many of the known shortfalls in the corporate (SL) EP&R arrangements have been addressed within the Magnox Reprocessing arrangements, a number are still outstanding but are not significant issues in their own right. In a number of instances, the MSRP lead for emergency arrangements has proactively put in place elements within the emergency arrangements which are to a better standard than that required by the corporate arrangements. Based on performance to date, MRSP is on target to meet the key EP&R performance target required by the corporate arrangements for testing (via drills and exercises) the emergency arrangements.
There is a comprehensive inventory of emergency equipment associated with MRSP Access Control Points (ACPs). There is an inventory of ACP equipment, and agreements are currently being put in place between MRSP and other facilities to undertake routine checks to assure its functionality, in the meantime the necessary checks are undertaken by MRSP. At the inspection, SL could not demonstrate that all fixed equipment claimed to perform an emergency management function was appropriately inspected, tested and maintained and was therefore capable of fulfilling its function at all times. Following the inspection, SL undertook a review to identify key fixed emergency equipment within MRSP which identified only two items, one of which is subject to an appropriate maintenance regime, the arrangements for the other are being reviewed by SL. I am satisfied SL is taking this issue seriously and is progressing it with suitable urgency. I have raised an issue for SL to confirm that appropriate arrangements are in place to ensure the functionality of key fixed equipment in MRSP. Whilst I identified this issue at MRSP, it is likely to be a site wide issue so I will inform ONR’s Infrastructure Site Inspector, who takes the lead for ONR for emergency arrangements of this potential site wide issue.
Many of the known shortfalls in the site EP&R arrangements have been addressed in MRSP, work to address the remaining shortfalls is well underway and those outstanding are not significant. Significant improvements have been made to emergency instructions and emergency response facilities over the last year, and more improvements are planned. In my opinion, the MRSP emergency response arrangements and capability currently meet and in some cases exceed the requirements of ONR’s guidance on LC11, for example in the nature of equipment available in the ACP to facilitate plant re-entry.
Whilst SL could not demonstrate appropriate arrangements were in place to ensure the functionality of all fixed emergency equipment within MRSP, I am reassured this is unlikely to be a significant issue. I have raised an issue for SL to confirm that appropriate arrangements are in place to ensure the functionality of key fixed equipment in MRSP and will monitor progress as part of my routine regulatory engagement with SL.
On balance, I judge an IIS rating of 3 (adequate) to be appropriate against LC11 – SL has made very significant improvements to the emergency arrangements in MRSP which reassures me that SL will be able to respond appropriately to an accident of emergency in MRSP.
I did identify that SL’s LC11 arrangements do not currently include the requirement for fixed equipment claimed to perform an emergency management function to be appropriately inspected, tested and maintained (or functionality to be demonstrated by some other reasonably practicable means). I have referred this issue to ONR’s lead for emergency arrangements on the Sellafield site.
Based on the evidence gathered, no significant matters have been identified that are likely to impact on nuclear safety on the Sellafield site at this time.