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, Decommissioning, Fuel and Waste (SDFW) Division. In accordance with that strategy, a Licence Condition (LC) compliance inspection of the Special Nuclear Materials Operating Unit (SNM OU) was carried out, as planned in November 2018.
The purpose of this planned inspection was for ONR to determine the adequacy of implementation of the licensee’s formal arrangements for compliance with LC11 (Emergency Arrangements). For the inspection, I focused on the evidence for compliance within Special Nuclear Material (South) (SNM (S)) facility.
On 7 November 2018, I, the site inspector for the SNM OU, undertook a planned Licence Condition 11(LC11) inspection within the SNM (S) facility. The SNM OU SL Nuclear Independent Oversight (NIO) representative participated in the inspection also.
The inspection comprised discussions with SL personnel, and reviews of SL records and documents.
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:
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 SNM (S) facility. The SNM (S) facility is within the THORP building. I sampled various Sellafield records and documentation and I judged that, on the evidence sampled, the licensee had implemented adequately their processes for compliance with LC11.
From the inspection sample I have seen evidence that SNM (S) are maintaining local arrangements, and there are clear linkages from those local arrangements through to the corporate arrangements as detailed in the Emergency Management Documentation Hierarchy.
SNM (S) has developed a detailed plan for undertaking emergency drills and exercises and that plan is regularly tested.
SNM (S) explained the key improvements they are implementing to manage command and control when THORP goes into Post Operational Clean Out (POCO) and discussed the details of the new Access Control Points (ACP). From the documentation sampled I have seen evidence that SNM (S) will have a robust process in place for emergency response when THORP moves into POCO.
There were no significant findings identified during my inspection, and I have not raised any associated Regulatory Issues.
I am of the opinion that SL, as the licensee, has adequately implemented its arrangements for compliance with License Condition 11.
The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.
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.
My findings were shared with and accepted by the licensee as part of normal inspection feedback. I have not raised any Regulatory Issues as a result of this inspection.