In accordance with the Office for Nuclear Regulation's (ONR's) Sellafield Strategy, each year ONR performs a series of planned compliance inspections of core licence conditions targeting those facilities with the potential to give rise to off-site effects to the public.
This planned, core licence condition inspection was carried out to assess Sellafield Ltd.'s (SL's) compliance with licence condition (LC) 11 – emergency arrangements and licence condition (LC) 24 – operating instructions, at the Thermal Oxide Reprocessing Plant (THORP) at Sellafield.
LC 11 requires SL to "make and implement adequate arrangements for dealing with any accident or emergency arising in the site and their effects."
LC 24 requires SL to "ensure that all operations which may affect safety are carried out in accordance with written instructions…"
I carried out two one day licence compliance inspections against licence conditions 11 and 24 utilising the following ONR inspection guidance:
N/A as this was not a safety systems inspection.
Overall I consider that SL was able to demonstrate much improved integration of its site and facility level emergency arrangements organisations, which is resulting in tangible improvements in a number of areas, such as in the facilities and equipment provided for use in emergencies.
THORP's management of its emergency arrangements is now being carried out in a more systematic and structured way with enhanced management direction and oversight.
The implementation/delivery of some emergency management major projects initiatives could nevertheless be improved. For example, I observed that in some instances project delivery and integration with the receiving plant (THORP in this case) is not as robust as could be the case, creating additional work to effectively implement identified improvements. I was however reassured by the fact that SL had already identified this issue independently and is taking steps to improve this by realigning the management structure for its Sellafield emergency management major projects.
It is my opinion that there have been significant improvements in the implementation of procedural use and adherence at THORP since my previous LC24 inspection. Procedural use and adherence standards appear to have been clearly communicated by the plant management and this is leading to compliant levels of performance now being achieved.
While I welcome these improvements, I stressed to the plant management that further work was needed to ensure recent gains become robustly embedded and that good practices now being achieved in some parts of THORP are replicated across the whole of the facility.
I commended the plant's management on the significant amount of effort they have expended on improving the quality of THORP's operating procedures and the systems/processes for updating these. I noted that this provides a good basis to support high procedural use and adherence standards.
On the basis of the evidence gathered during the inspection, I judge that inspection ratings of GREEN (No formal action) are appropriate for compliance against both LC 11 (Emergency arrangements) and LC 24 (Operating instructions). This is because I found SL to be compliant with its legal duties with only minor areas for further improvement being identified.