Office for Nuclear Regulation

Routine LC 11 and LC24 Compliance Inspection

Executive summary

Purpose of intervention

In accordance with the Office for Nuclear Regulation’s (ONR’s) Sellafield Strategy, each year ONR performs a series of planned compliance inspections of core licence conditions targeted at those facilities with the potential to give rise to offsite effects to the public. This core licence condition inspection was performed to assess Sellafield Ltd.’s compliance with Licence Condition 11; Emergency Arrangements, and Licence Condition 24; Operating Instructions, in the Thermal Oxide Reprocessing Plant (THORP).

Interventions Carried Out by ONR

Supported by two ONR Specialist Inspectors, I carried out a planned two and half day compliance inspection against LC11; Emergency Arrangements, utilising ONR guidance NS-INSP-GD-011 Revision 3, and against LC24, Operating Instructions, utilising ONR guidance NS-INSP-GD-024 Revision 2. In addition, I held an information sharing session with senior members of the THORP management team to discuss on-going regulatory issues.

Explanation of Judgement if Safety System Not Judged to be Adequate

N/a as this was not a safety systems inspection.

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

LC11 Emergency Arrangements

It is my opinion that Sellafield Ltd are now utilising an appropriate, comprehensive plan to control and integrate improvements to THORP’s emergency response capabilities as a result of both local and site wide initiatives. Furthermore, I noted that THORP management have self-identified a number of issues regarding their compliance with site standards for managing emergency response equipment. These were identified by them during what I consider to be a comprehensive review and Sellafield Ltd appears to making suitable progress with their remedial actions to achieve compliance with this guidance in THORP.

LC24 Operating Instructions

I noted that Sellafield Ltd were able to demonstrate that significant effort had been expended in THORP in the production and roll out of high quality training material regarding the use of operating instructions, procedures and adherence to them. It was my opinion, however, that whilst the leadership team had been effective in reinforcing standards in the maintenance teams, a similar effectiveness was not evident to me amongst the operators in the central control room. It was my opinion that some personnel appeared to be unclear about management’s revised standards and their expectations of them.

With regard to supervision, it was unclear to me whether the current management/leadership structure provides sufficient oversight and support to the shift team managers (STMs) to ensure that the required changes in culture and expectations are delivered to an appropriate timescale. I also observed an example of non-approved procedures being available in the workplace.

Conclusion of Intervention

LC 11 Emergency Arrangements

Due to the significant progress that Sellafield Ltd has made in the integration and delivery of the various corporate emergency management improvement plans into the THORP local emergency arrangements plan, it is my opinion that that an IIS rating of 3 (adequate) for compliance against LC11 is appropriate. I now have significantly increased confidence that tangible improvements to the facility’s emergency arrangements will continue to be delivered.

Although it was my opinion that the current standard of emergency equipment management was not in line with Sellafield Ltd.’s site standards, I consider the fact that THORP management have self-identified the pertinent issues through a suitably robust process and put in place a comprehensive plan to address these is commendable, hence, overall I consider this supports an overall IIS rating of 3 (Adequate).

LC24 Operating Instructions

Overall, for compliance against LC24 I consider that that an IIS rating of 4 (below standard) is appropriate. Whilst Sellafield Ltd has made significant progress in rolling out a procedural use and adherence improvement training programme in THORP, it is my opinion that this has not resulted in uniform improvements in procedural use and adherence knowledge and implementation across THORP. As such, I consider that Sellafield Ltd needs to address the observed disconnect between the setting of appropriate standards at leadership levels and behavioural changes in front line operations in THORP.