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 2016 - March 2017), 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 Decommissioning Directorate is adequately implementing SL's site-wide arrangements and directorate specific arrangements for compliance with Licence Condition 11 (emergency arrangements). The intervention targeted the implementation of SL's arrangements within Pile Fuel Cladding Silo (PFCS), a facility about to undertake operations to retrieve stored wastes from the silos as part of the hazard and risk reduction programme across the Legacy Ponds and Silos estate at Sellafield. It is important, therefore, that the facility's emergency arrangements are adequate and that ONR has confidence that the Licensee's response to any foreseeable event will appropriate and effective. This inspection is complementary to ONR's inspection of SL's site wide demonstration of compliance with LC 11 emergency arrangements that is led by ONR's infrastructure inspector.
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 adequately implemented its arrangements for compliance with LC11. I consider the Decommissioning Directorate'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. The use of cross decommissioning resources provides good emergency staffing and equipment coverage across the legacy ponds and silos and, in this case, in PFCS facility specifically.
These findings were, however, offset by the need for minor improvements such as consistency of wording in instruction documents, improving the planning and management of exercises, checking that emergency response team role assessment specifications reflect the correct training requirements, the need to formalise the conduct of emergency equipment peer review checks.
Consequently, on balance, I consider the inspection merits an IIS rating of GREEN (no action required) against LC11.
My findings regarding those areas where I noted opportunities for minor improvements were accepted by the Decommissioning security and resilience team and the PFCS facility team.
My findings were shared with, and accepted by, the licensee as part of normal inspection feedback. I will follow up the training observation regarding SL's OPMS system with ONR's Corporate Inspector. The SL internal regulator is already addressing the need to improve the planning and management of exercises. Hence, I do not consider it to necessary to raise any specific Regulatory Issues as a result of this inspection.