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, a Licence Condition (LC) compliance inspection was carried out on the Magnox Operating Unit (OU), as planned.

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) was selected as the target for the LC11 inspection, as effective emergency management is a cornerstone safety claim within that plant, given the relative age of the equipment within the facilities, and the hazardous nature of fuel reprocessing.

Intervention Carried Out by ONR

On 24-25 July 2019, I carried out an 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 MRF, 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 MRF, and I examined a sample of SL’s emergency 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 MRF Incident Control Centre, Access Control Point and the Re-Entry Preparation Area (REPA), all locations were well organised.  I noted that it was not clear whose responsibility it was to ensure that the REPA had sufficient amounts of the required equipment. I have therefore raised the following regulatory finding:

SL to ensure that there are clear arrangements and ownership for the maintenance and replacement of emergency equipment in the MRF.

This has been raised as a Regulatory Issue which will be managed as part of normal regulatory business.

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.

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. I therefore consider that an inspection rating of Green (No Formal Action) is merited.