Office for Nuclear Regulation

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Planned Licence Compliance Inspection Covering LC11 Emergency Arrangements and LC36 Organisational Capability

Executive summary

Purpose of Intervention

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 the PP1 inspection plan for the Plutonium Finishing and Storage facilities Operating Unit (PF&S OU), Licence Condition (LC) compliance inspections were carried in November 2017.

The purpose of this inspection was for ONR to determine the adequacy of the implementation of SL's arrangements for compliance with LC 11 (emergency arrangements) and LC 36 (organisational capability).

The inspection took place in PMF(N), given the on-going improvements to the ventilation systems and the storage of Special Nuclear Materials (SNM) in an ageing facility.

Interventions Carried Out by ONR

I carried out planned compliance inspections against licence conditions 11 and 36. The inspections consisted of observing a facility-based shift emergency exercise, discussions with relevant staff and sampling relevant documentation. Sellafield's Nuclear Independent Oversight (NIO) and a Prospect Safety Representative participated in the inspections.

LC 11 requires the licensee to make and implement adequate arrangements for dealing with any accident or emergency arising on the site and their effects. The following ONR guidance was used:

LC 36 requires the licensee to provide and maintain adequate financial and human resources to ensure the safe operation on the licensed site. The following ONR guidance was used:

Explanation of Judgement if Safety System Not Judged to be Adequate

This was not a system based inspection, therefore no judgement has been made on the adequacy of implementation of the safety case.

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

I observed PMF(N) conduct a emergency exercise based on the loss of the facility ventilation. In my opinion, SL demonstrated an adequate response to the event, the fault was correctly diagnosed and the countermeasures specified in the facility emergency instructions were implemented in an effective and timely manner. I am satisfied that SL critically evaluated its own performance during the exercise and has identified actions to further improve its emergency response.

I examined the nuclear baseline, minimum safe manning levels and the management of change in PMF(N). Based on my sample, I am satisfied that SL has adequately defined its nuclear baseline and is proactively managing its compliance. I am content that the evidence provided by SL demonstrates that the minimum safe manning level for PMF(N) has been appropriately determined, and is being complied with. I am satisfied that the Management of Organisational Changes are being raised, categorised and implemented in accordance with SL site arrangements.

Conclusion of Intervention

Based on the evidence sampled during these inspections, I judge SL has adequately implemented its arrangements for compliance with LC 11 and LC 36. I therefore consider that inspection ratings of Green (no formal action) are appropriate against LC 11 and LC 36 in accordance with ONR assessment rating guidance.