Office for Nuclear Regulation

Special Nuclear Materials (SNM) - Compliance inspection of Licence Condition 11 (Emergency arrangements)

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 selected licence conditions, targeted at those facilities with significant importance to nuclear safety.

This record describes the outcome from the planned intervention undertaken to determine if the SNM Value Stream has adequately implemented Sellafield Limited’s (SL) site-wide arrangements and local specific arrangements for compliance with Licence Condition (LC) 11 (Emergency arrangements).

This inspection is complementary to ONR’s inspection of SL’s site wide demonstration of compliance with LC 11 (Emergency arrangements).

Interventions Carried Out by ONR

Licence Condition 11 requires the licensee to make and implement adequate arrangements for dealing with any accident or emergency arising on the site and their effects. 

The inspection comprised discussions with SL staff, examination of plant documentation and inspection of facilities and equipment. It focussed on the following areas:

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

I saw evidence that the DAPs on duty on the day were SQEP for their emergency roles. During the plant walkdown in SNM (S), I saw evidence that the Access Control Points were appropriately set up and stocked. Based upon sampling of submitted documents, discussions with SL staff and a facility walk-down, I found that SNM has complied with requirements of the LC 11 arrangements in place. I identified one minor compliance shortfall in relation to the back-up Emergency Operating Instruction updates in the Incident Control Centre which will be followed up as a level 4 (i.e. lowest level) Regulatory Issue (RI).

In response to the COVID-19 pandemic, SL has developed variations to its corporate LC 11 arrangements in order to introduce some flexibility but in a way which still maintains compliance with legal obligations. Prior to this intervention, ONR has reviewed the relevant variations and is satisfied that they are adequate. In this inspection I found that SNM had applied the LC 11 variation in an appropriate way.

Notwithstanding the minor compliance shortfall identified above, it is ONR’s opinion that the licensee has adequately implemented its arrangements for compliance with LC 11. The staff interviewed had a good knowledge of the extant arrangements and provided some satisfactorily supporting evidence. The use of cross plant resource agreements provides sufficient emergency staffing levels and equipment coverage.

Conclusion of Intervention

On the basis of the evidence gathered during the inspections, I judge that an inspection rating of GREEN (No Formal Action) is appropriate for compliance against LC 11 given that SL has adequately implemented its corporate arrangements for this LC.