The Office for Nuclear Regulation (ONR) undertakes all regulatory interactions with Sellafield Limited (SL), the site licensee, against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. The planned inspection schedule for the current regulatory year (covering April 2018 – March 2019), the content of which is guided by that strategy, identifies the Licence Conditions (LCs) that will be inspected over this period.
This intervention was conducted to determine, through a partial re-demonstration of an emergency exercise that the site is implementing adequately its site-wide arrangements for compliance with Licence Condition 11 (Emergency arrangements). This intervention fulfils the requirement set by ONR for SL to demonstrate the site’s emergency management capability on an annual basis, based on a safety-driven scenario.
Licence Condition 11 (LC11) requires the licensee to make and implement adequate arrangements to deal with any accident or emergency arising on the site and to ensure that such arrangements are rehearsed periodically.
ONR’s inspection that comprised an assessment of a partial re-demonstration of an emergency exercise was planned and managed by the licensee, and was conducted in accordance with the following ONR guidance:
Through discussion with ONR, SL prepared a challenging scenario for this partial exercise that focussed around a significant loss of containment event caused by seismic tremors and associated aftershocks. The scenario was designed to test SL’s emergency capability and response, with a focus on certain facilities that either experienced simulated loss of containment or were affected by the event. The scenario required specific nuclear and radiological challenges to be assessed and resolved / mitigated by SL during the course of the exercise. It also rehearsed a number of challenging aspects as the event had the potential to escalate to a Severe Accident Management Strategy (SAMS) event.
The exercise was assessed by a multi-discipline team of five ONR inspectors located at strategic positions around the site.
Not applicable; this was not a Safety System inspection.
This was a challenging exercise scenario that placed demands on organisation across the site, as well as significantly challenging SL’s unified command and control.
Overall, I consider that SL demonstrated an adequate emergency response performance in this exercise. My assessment team and I consider that SL would have coped adequately had this been an actual event, and as such, I awarded a Green rating.
I noted some areas of good practice e.g. all casualties were rescued in a timely and effective manner, plus the roll-call in the affected facility was conducted timely and efficiently. In addition, the unified command and control performance was judged to be good within the Incident Control Centre.
ONR welcomed the licensee’s alignment of its self-assessment findings to ONR’s findings, through the licensee being open, and self-critical. However, I plan to raise a Regulatory Issue to follow up, as normal regulatory business, the identified minor areas for improvement.
ONR shared its observations with SL at a Hot Debrief session that was held the day following the exercise. I welcomed the strong degree of alignment between ONR observations, those of SL’s and of SL’s Nuclear Independent Oversight, who performed a concurrent evaluation of the emergency exercise.
I plan to raise a Regulatory Issue to follow up the identified areas for improvement.
Overall, based on SL’s demonstration, I consider that the licensee has implemented effectively its arrangements for compliance with LC11 and I therefore awarded a rating of Green (No formal action) to this inspection.