The Office for Nuclear Regulation (ONR) undertakes all regulatory interactions with the Sellafield site licensee (Sellafield Limited, SL) against a strategy defined by the ONR Sellafield Sub Division. In accordance with that strategy, a planned Licence Condition 11 (LC) compliance inspection was carried out on the Spent Fuel Management value stream Highly Active Liquor Evaporation and Storage (HALES) facility.
The purpose of this inspection was for the ONR to determine the adequacy of implementation of the licensee’s formal arrangements for compliance with LC11 (emergency arrangements). The inspection comprised of discussions with SL staff and a review of emergency response records.
In particular this inspection targeted:
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.
I undertook a review of the HALES Emergency Operating Instructions (EOI) in use, how and when the Incident Control Centre is set up, the personnel involved and how the emergency equipment is checked and maintained. From the evidence sampled I was satisfied that the documented emergency arrangements in place for the response to an emergency were adequate.
I sampled the training records for an Incident Controller and a Deputy Incident Controller and found them to have completed their required training and their SQEP status to be in date. It was noted that the role profiles for the emergency responders had been changed, with a number of previously required training courses being moved to recommended courses. The recommended training from the emergency response SQEP profiles are in connection with communication and situational awareness and it is at the discretion of the employee or their line manager whether the training is undertaken. There is the potential that these recommended training courses may be missed for those people who would benefit from them to perform their emergency response roles effectively; however it will not be a barrier to them attaining SQEP status. This information has been provided to the ONR Sellafield Corporate Inspectors for action, as appropriate.
SL have put in place an emergency response strategy that outlines how the EOIs will be exercised over the next five years and how they ensure that each shift exercises each EOI. Overall, I was satisfied that the exercise strategy and programme were adequate. I selected two of the HALES emergency drills and exercise reports and noted that these had been completed to an adequate standard. From the exercise reports sampled, SL was not able to demonstrate how they had tracked and closed out the learning that had arisen as a result. Accordingly, I have raised a Level 4 regulatory issue for the facility to address this.
Notwithstanding this, overall I judge that, on the basis of evidence sampled at the time of this inspection, the licensee has adequately implemented its arrangements for compliance with Licence Condition 11 (Emergency Arrangements). I therefore consider that the required standard was met and an inspection rating of Green is merited (no formal action).
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 gathered during this intervention, I do not consider there to be any matters that have the potential to impact significantly on nuclear safety.
At present, no additional regulatory action is needed over and above the planned interventions within the Spent Fuel Management Value Stream at the Sellafield Nuclear Site as set out in the Integrated Intervention Strategy, which will continue as planned.