The Office for Nuclear Regulation (ONR) undertakes all its regulatory interactions with the Sellafield site licensee, Sellafield Ltd (SL), against a strategy defined by the ONR Sellafield Programme. Within this strategy, ONR inspects SL’s Licence Condition (LC) adequate arrangements according to a five-year rolling programme. This inspection of SL’s arrangements for LC11 (Emergency arrangements) is part of that programme.
LC11 requires the licensee to make and implement adequate arrangements for dealing with any accident or emergency arising on the site and their effects.
I completed an on-site inspection, which lasted two working days, carrying out a series of interviews with SL staff. The compliance inspection was undertaken in accordance with the following ONR processes and supporting inspection guidance:
N/A. This was not a Safety System inspection.
The inspection identified that there are a number of areas in which the formal arrangements for emergency management are currently inadequate, either in terms of required capabilities, or the extent of their incorporation across all site documentation.
Where arrangements are in place, they are not always consistently applied at both site and facility level, with individual facilities taking different approaches to the delivery of internal Emergency Preparedness & Response (EP&R) capability, and thus formal articulation of what is required.
However, the inspection confirmed that all of these shortfalls have already been recognised by the licensee, and that funded programmes exist to address the gaps. Additionally, there is an ongoing intervention being undertaken by ONR to ensure these shortfalls are addressed in a timely manner.
Whilst the extent of shortfalls in the arrangements remains a concern, it is one that has been recognised and reacted to, and the licensee has been proactive and open throughout the inspection, seeking to clarify all recognised deficiencies and how they will be addressed.
I consider that the licensee currently has LC11 arrangements that are below the standard expected and so have awarded an IIS rating of 4 (below standard). I have however noted that, against these shortfalls (which are already identified), SL have a recovery programme in place which is being overseen by an ONR intervention.
The site emergency arrangements are a key claim in the mitigation of the hazards that are managed at the site. Noting this, I consider that it is proportionate to undertake a more frequent review of the EP&R capability at site, to confirm that the expected pace of improvements in the arrangements are achieved. I have therefore raised a Regulatory Issue on the ONR Issues Database to track this activity.