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 planned intervention was undertaken to determine if the Infrastructure organisation is adequately implementing SL’s site-wide arrangements for compliance with Licence Condition 11 (Emergency arrangements). The intervention targeted the implementation of Sellafield Ltd.’s arrangements within Package Management and Railways (PM&R). PM&R encompasses the movement of spent fuel flasks within the Sellafield site as well as the maintenance of these flasks to support their use to transport spent fuel from nuclear power stations within the UK to the Sellafield licensed site for reprocessing. PM&R also maintains other flasks and packages used to transport radioactive materials within the licensed site. This inspection is complementary to inspection activity undertaken by ONR transport inspectors who focus on compliance with the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009.
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 staff, examination of plant documentation, and inspection of facilities and equipment, focussed on the following areas:
Not applicable; this was not a Safety System inspection.
It is my opinion that the licensee has only effectively implemented some of its arrangements for compliance with LC11 and that my findings regarding those areas where improvements are required align with the findings from SL’s self-assessment of their compliance status.
I consider the organisation’s implementation of the site’s arrangements for LC11 is good in some areas; for instance, the staff interviewed had a good knowledge of the extant arrangements and provided some good supporting evidence. This is, however, offset by the need for improvements such as further work needed to improve the variety and nature of future emergency exercises to provide more opportunities for live play to fully test the arrangements, identify weakness, and identify areas for improvements. Consequently, on balance, I consider the inspection merits an IIS rating of 4 (Below Standard), against LC11.
My findings were shared with, and accepted by, the licensee as part of normal inspection feedback. I have raised one Regulatory Issue as a result of this inspection, which identifies the need for SL to plan and implement the improvement programme that it has already identified and will enable ONR to track its progress to an adequate conclusion.