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 Sub Division. In accordance with that strategy, Licence Condition (LC) compliance inspections were carried out on the Magnox Operating Unit (OU), as planned, in September 2017.
The purpose of this inspection was for the ONR to determine the adequacy of implementation of the licensee's formal arrangements for compliance with LC 11 (emergency management) and LC 12 (DAP and SQEP).
The Magnox Reprocessing Facility (MRF) and Magnox East River (MER) plants were selected as the targets for the LC11 inspection, as effective emergency management (EM) is a cornerstone safety claim within those plants, given the relative age of the equipment within those facilities, and the hazardous nature of fuel reprocessing and used fuel handling/storage.
Calder Hall was selected as the target for the LC12 inspection, as adequate control of the qualification of those DAP overseeing the defuelling procedures contributes to the evidence in support of fuel-free verification within each of the four reactors, for which ONR may need to formally consider a related safety and/or security permission.
On 11 and 14 September 2017, I carried out a two-day, on-site licence condition compliance inspection of facilities within the Magnox Operating Unit. The inspection comprised discussions with SL staff, a targeted plant walk down, observation of and interviews with operational staff, and reviews of plant records and other documentation.
Both licence conditions require SL to make and implement adequate arrangements for dealing with any accident or emergency arising on the site (LC 11), and to ensure that only suitably qualified and experience persons perform any duties which may affect the safety of operations on the site (LC 12). As part of my preparation for the delivery of this intervention, the following formal ONR guidance documentation was used:
This was not a system based inspection, and therefore no judgement has been made of the adequacy of implementation of any part of the safety case.
During my inspection, I sampled evidence associated with the licensee's compliance with its formal arrangements for responding to emergencies within the MER and MRF, and examined a sample of SL's equipment, including evidence of the management of its condition. I judged that, on the evidence sampled, the licensee had implemented adequately their processes for the management of operating rules.
Of particular note was the drive for continuous improvements in the delivery of effective drills and exercises within the MRF since my last compliance inspection. There were a number of initiatives being delivered (and some planned) which were seeking to enhance the team learning that the MRF currently gained from the delivery of EM training on plant. In my opinion, this progression is driven by the work of the Spent Fuel Management (SFM) emergency planner allocated to MRF; the required legal standard in this particular area of EM capability is achieved as a direct result of their efforts.
I examined the quality of training and assessment for senior operations staff within Calder Hall, with particular focus on the way in which the management team ensure that those DAP with responsibility for the defuelling tasks are judged to be suitably qualified and experienced. In my opinion, on the evidence sampled, the licensee had implemented adequately their processes for that assessment, including the provision of a suitably adaptable training scheme.
I consider that the licensee has complied with all legal duties, and that there are only limited opportunities for further ALARP improvements. Therefore, it is my opinion that, against compliance with Licence Conditions 11 and 12, an inspection rating of Green (No Formal Action) is merited.
From those areas sampled, I did not identify any significant shortfalls in the licensee's formal arrangements for compliance which would prompt an inspection of those arrangements earlier than currently planned.
From the evidence sampled during these inspections, I judge that there was sufficient evidence that the licensee's formal arrangements for compliance with Licence Conditions 11 and 12 are being implemented adequately.