Office for Nuclear Regulation

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Intervention to discuss the Management of the proposed reduction to the 'on site' Fire & Rescue Service and Unannounced Inspection of an aspect of the 'on site' Emergency Arrangements

Executive summary

Purpose of intervention

An intervention was made at Springfields Fuels Limited, primarily to inspect aspects of the management of the proposed changes to the ‘on site’ Fire & Rescue Service, together with an unannounced inspection of an aspect of the ‘on site’ emergency arrangements.

Interventions Carried Out by ONR

A planned intervention was made, primarily to inspect aspects of the management of the proposed changes to the emergency arrangements arising from the proposed reduction in the size of the ‘on site’ Fire & Rescue Service.  The justification was founded upon the recent cessation of uranium hexafluoride production at the site, which resulted in revised risk assessments.  I was accompanied by a fire safety specialist inspector and an organisational change specialist inspector, providing regulatory advice to the licensee on a range of aspects of the proposed changes to the ‘on site’ emergency arrangements, which was well received by the licensee.

Related to the proposed change to the strength of the ‘on site’ fire and Rescue Service, I decided to conduct an unannounced inspection of an aspect of the emergency arrangements, at the Emergency Control Centre, (ECC). 

The licensee provided an update on the licensee’s investigation into the recent event reported to ONR relating to a shortfall in the implementation of criticality control arrangements.

I provided regulatory advice to the licensee relating to the planning of a forthcoming joint Level One and Level Two emergency exercise. 

A brief but constructive information exchange meeting was held with the licensee’s Managing Director

Explanation of Judgement if Safety System Not Judged to be Adequate

No safety system inspection was undertaken, hence this was not applicable.

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

The licensee adequately demonstrated due consideration of the implications for the ‘on site’ licence condition 11 emergency arrangements of the proposed reduction in the strength of the ‘on site’ Fire and Rescue Service, from a shift strength of six to five fire fighters proving 24/7 coverage.  The licensee’s fire, leakage and criticality risk assessments had been revised, to reflect the cessation of uranium hexafluoride production.  The licensee was receptive to the regulatory advice provided in relation to the drafting of the related licence condition 36 management of change safety justification, which was to be finalised, presented to the nuclear safety committee and then presented to ONR for assessment. 

For the unannounced inspection of an aspect of the ‘on site’ emergency arrangements, the licensee effectively demonstrated the timely replacement of a fire fighter, who was manning the ECC, by a health physics monitor, to promptly release the fire fighter to attend the simulated call to an ‘on site’ building fire.  This arrangement was proposed to be maintained after the organisational change, but given the proposed reduction in shift strength of the team of fire fighters, the timely release of the fire fighter from the Emergency Control Centre would be of greater importance.

I confirmed that the licensee was currently adequately investigating a recent event, which had been reported to ONR, relating to a shortfall in the implementation of the criticality control arrangements.  

For the proposed joint Level One and Level Two emergency exercise, the scenarios will require careful planning to achieve an adequately testing Level One exercise as well as sustaining a robust Level Two emergency exercise.  Some potential emergency exercise scenario details were discussed with the licensee, my regulatory advice informing the planning of the joint emergency exercise, by both the licensee and the local authority. 

The brief information exchange meeting with the Managing Director did not warrant an inspection rating.

Conclusion of Intervention

On balance, I concluded that an inspecting rating of “3”, adequate, was warranted for the initial management of the proposed reduction to the size of the ‘on site’ Fire and Rescue Service.  The organisational capability management of change documentation was only at a draft stage, so no inspection rating was warranted for licence condition 36.

I decided to conduct an unannounced inspection of an aspect of the ‘on site’ emergency arrangement related to the proposed reduction in the shift strength of the ‘on site’ fire and rescue service. The licensee adequately demonstrated this aspect of the emergency arrangements.  This was only a limited inspection of the emergency arrangements, so no inspection rating was warranted.

Regarding the recent criticality control event reported to ONR, I concluded that the licensee was appropriately investigating this event.  No inspection rating was warranted for this brief meeting.

The regulatory advice which I provided on the planning of the forthcoming joint Level One and Level Two emergency exercise was accepted by the licensee.  No inspection rating was warranted for this meeting.

The brief information exchange meeting with the Managing Director did not warrant an inspection rating.