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. In accordance with that Strategy, a Licence Condition compliance inspection of the High Level Waste Plant (HLWP) Operating Unit (OU) was carried out as identified within the planned inspection schedule for Operational Waste Facilities.
This planned intervention was undertaken to determine if the HLWP OU is adequately implementing SL’s site-wide arrangements for compliance with Licence Condition 11 (emergency arrangements). The HLWP OU was chosen because of the radiological hazard associated with its facilities.
Licence Condition 11 (LC11) requires SL to make and implement adequate arrangements for dealing with any accident or emergency arising on the site and their effects.
I carried out a one-day, on-site, licence condition compliance inspection of the HLWP OU. Subsequent to the compliance inspection I held a number of routine intelligence gathering meetings.
The inspection comprised discussions with SL staff, a partial plant walk down, and examination of a sample of SL procedures and instructions. The inspections were carried out in accordance with the following formal ONR inspection and assessment guidance:
‘LC11 - Emergency Arrangements’, NS-INSP-GD-011 Rev 4, June 2016
N/A; this was not a Systems Based Inspection (SBI).
SL accepted my observation that the management of information relating to training and competence of emergency scheme staff could be improved, to enable the evidence to demonstrate that training has been completed is recorded and communicated more effectively. For example, records of attendance for individuals that have participated in emergency exercise drills are not formally recorded, when this information would make a valid contribution to demonstrate the competence of staff. I have amended an existing minor Regulatory Issue to reflect this, and I will follow up the closure of this issue during future routine regulatory engagements. Overall, however, from the evidence sampled during this inspection, I consider that SL has effectively implemented its arrangements for compliance with Licence Condition 11, and I have therefore assigned an inspection rating of Green (No Formal Action).
My findings were shared with, and accepted by SL, as part of routine inspection feedback. I have amended one existing minor Regulatory Issue as a result of this inspection. This amended Regulatory Issue places an expectation on SL to improve the administrative and visibility of records to assist in efficiently demonstrating that individuals with emergency arrangements responsibilities in both the HLWP and HALES OUs are suitably trained and competent.