The purpose of this planned intervention was to perform a Licence Condition (LC) compliance inspection against LC 11 in the Plutonium Manufacturing Facilities (North) P
MF (N) on Sellafield Ltd.’s (SL) nuclear licensed site at Sellafield, Cumbria.
The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Sellafield site licensee (Sellafield Limited, SL) against a strategy defined by the ONR Sellafield Programme. The inspection plan PP1 for the plutonium finishing and storage facilities (PF&S) details a strategic programme of regulatory inspections which includes licence compliance inspections of the Plutonium Management Facilities.
Licence condition 11 requires the licensee to have adequate arrangements for dealing with incidents and emergencies on the site. Inspection of these arrangements in PR&S is considered important due to the presence of plutonium product in aging facilities.
The LC 11 inspection consisted of observing a facility-based emergency exercise, conducting one to one discussions with relevant staff and sampling relevant documentation.
This was not a safety system inspection.
Whilst it was clear that much improvement has taken place, it was my opinion that there are still some shortfalls when compared against ONR guidance for LC 11. In particular, there were issues with the availability of suitably SQEP persons to staff the Incident Control Centre (ICC), a lack of adequate emergency and fire detection systems and several shortfalls against suitable command and control process and procedure.
The key findings of the intervention are as follows:
It is my opinion that the exercise and subsequent discussions demonstrated that much progress had been made in improving the standard of emergency response in PMF (N). On the day, however, the exercise showed that more work is required to reach an adequate standard when judged against relevant good practice and ONR guidance. Consequently, it is my opinion that an IIS rating of 4 (below standard) is considered appropriate because there were specific procedural weaknesses and examples where persons were observed not following proper exercise procedure.
A number of level 3 regulatory issues have been raised to cover the key findings as listed above and to ensure they are properly tracked and regulated.