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, Decommissioning, Fuel and Waste (SDFW) Division. The planned inspection schedule for the current regulatory year (covering April 2017 - March 2018), the content of which is guided by that strategy, identifies the Licence Conditions (LCs) that will be inspected over this period.
This unannounced inspection was undertaken to determine if SL's Analytical Services Facility is adequately implementing the licensee's site-wide arrangements for compliance with Licence Condition 11 (Emergency arrangements). The Analytical Services facility provides a number of important roles (e.g. material characterisation, chemical, physical and radiometric measurement and analysis) that support the safety of Sellafield site-wide operating facilities, including its high hazard and risk reduction work. This intervention focussed on inspection of Analytical Services Facility's access control points.
The overall adequacy of SL's site-wide LC 11 arrangements is considered separately in other ONR inspections.
Licence Condition 11 (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.
My inspection, which comprised discussions with licensee staff, examination of plant documentation, and inspection of facilities and equipment, focussed on implementation of Sellafield Ltd's arrangements:
Not applicable; this was not a safety system based inspection.
The licensee demonstrated some areas of good practice, and I identified some areas for improvement that were accepted by the licensee.
I consider the implementation of the licensee's arrangements for LC 11 within the Analytical Services Facility is good in several areas. For instance, it has adequately defined and substantiated the minimum safety manning levels for the facility. However, I consider my inspection identified shortfalls relating to the licensee being able to demonstrate with an adequate level of evidence that the persons assigned to meet minimum safety manning levels are suitably qualified and experienced. In addition, the licensee was unable to demonstrate that Access Control Point equipment is able to reliably function on demand.
For these reasons, and on balance, I consider that an inspection rating of Amber (Seek Improvement) is merited against LC 11 as a result of this inspection.
My findings were shared with and accepted by the licensee as part of normal inspection feedback. I have also raised a Level 3 Regulatory Issue as a result of this inspection requiring SL's Analytical Services Facility to review and demonstrate its LC 11 emergency arrangements meet relevant good practice.