Office for Nuclear Regulation

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Compliance inspection of Licence Condition 11 (emergency arrangements)

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 that strategy, Licence Condition (LC) compliance inspections were carried out on the Magnox Operating Unit (OU), as planned, in October 2018. 

The purpose of this inspection was for ONR to determine the adequacy of implementation of the licensee’s formal arrangements for compliance with LC 11 (emergency arrangements). 

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.

Intervention Carried Out by ONR

On 9 October 2018, I carried out a one-day, on-site licence condition compliance inspection of facilities within the Magnox OU. The inspection comprised discussions with SL staff, a targeted plant walk down of MER, observation of and interviews with operational staff, and reviews of plant records and other documentation.

LC 11 requires SL to make and implement adequate arrangements for dealing with any accident or emergency arising on the site. As part of my preparation for the delivery of this intervention, the following formal ONR guidance documentation was used:

Explanation of Judgement if Safety System Not Judged to be Adequate

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.

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

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 compliance with LC11.

I inspected the MER Incident Control Centre, B333 Access Control Point and a Forward Control Point, all locations were well organised with a systematic maintenance regime. A MER Duty Incident Controller demonstrated an adequate knowledge of the hazards and associated emergency arrangements for the facility and I observed that improvement activities are on-going.

From the inspection sample I have seen evidence that Magnox OU are maintaining local arrangements, they have a drill and exercise plan that has been developed in a structured manner and that is being implemented in a timely manner. As accepted by MER, the MER drill and exercise plan needs to be aligned with the 2017-2018 requirements provided in the MER 5-year rolling schedule for emergency drills and exercises.

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 Condition 11, 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. 

Conclusion of Intervention

From the evidence sampled during this inspection, I judge that there was sufficient evidence that the licensee’s formal arrangements for compliance with Licence Condition 11 are being implemented adequately.