- Site: Sellafield
- IR number: 22-030
- Date: June 2022
- LC numbers: 11
Purpose of Intervention
The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Sellafield site licensee (Sellafield Ltd) against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. The planned inspection schedule for 2022/23, identifies the Licence Conditions (LCs) that will be inspected during this period.
The purpose of this inspection was for ONR to determine the adequacy of implementation of Sellafield Ltd ’s arrangements for compliance with LC11 (Emergency arrangements) at Spent Fuel Services (SFS).
The overall adequacy of Sellafield Ltd’s site-wide LC11 arrangements is considered separately in other ONR interventions.
Interventions Carried Out by ONR
The intervention was undertaken by two inspectors, for brevity within this record, inspectors’ views are referred to as ‘I’ throughout.
I carried out a planned LC11 compliance inspection at SFS. The inspection focused on gaining assurance that SFS is compliant with Sellafield Ltd’s arrangements for: LC11 (Emergency arrangements).
Explanation of Judgement if Safety System Not Judged to be Adequate
Not applicable since this was not a safety system based inspection.
Key Findings, Inspector’s Opinions and Reasons for Judgements Made
I found that, overall, SFS has planned and implemented rehearsal (drills and exercises) programmes across all three of its areas (MAGNOX East River (MER), Fuel Storage (North) and Fuel Storage (South)). SFS provided evidence that these plans had been presented to the Management Safety Committee (MSC) for approval for the previous year and were in the process of submission for this year. Programmes were sampled and evidence of rehearsals being undertaken were provided.
However, I found that for Security and Resilience (S&R) led rehearsals, there was a significant period of non-delivery for MER facilities in 2021. In addition, I found some issues with the storage of and access to records of plant led exercises. Both of these issues were exacerbated by the COVID-19 pandemic and by unplanned leave within the respective teams. However, MER was able to provide evidence that it had delivered a programme of plant led drills and exercises during the period.
I was satisfied that delivery of a programme of S&R led rehearsals at MER has commenced, albeit subject to final development and approval for the year. To assure myself that the rehearsal programme is approved, I have raised a Level 4 (lowest level) regulatory issue. For the other facilities sampled (SFS (North) and (SFS South)) I found that appropriate rehearsal plans for this year are developed and are planned to be submitted for approval at the June MSC.
In sampling training records for the members of the MER emergency organisation against the Suitably Qualified and Experience Persons (SQEP) Role profiles, I found that two staff members undertaking SQEP roles on the shift on duty at the time of the inspection had certification for training that had expired. I advised SFS to follow its decision-making process and to immediately put in place appropriate mitigation measures for this identified shortfall. I have raised a regulatory issue to capture this shortfall, and for SFS to provide evidence that the extent of condition is understood and that all personnel with SQEP Roles within the emergency duty teams are qualified.
I found that equipment required for emergency response was available and in an adequate condition at the locations sampled. I also found that up to date emergency instructions were available.
My findings were shared with, acknowledged and accepted by SFS’s Head of Operations.
Conclusion of Intervention
Overall I found that a series of rehearsals have been undertaken for the previous year, and a programme is being implemented for this year. Emergency equipment is available and is in a good condition. I did identify shortfalls in relation to last year’s rehearsals at one facility and with Sellafield demonstrating members of its emergency duty team were qualified. However, I was satisfied with the immediate response taken by SFS to mitigate the compliance gaps regarding training in the short term, and with the proposed programme to address past shortfalls in rehearsals at MER. On this basis I have rated the inspection as GREEN (no formal action). I will follow up the shortfalls identified with the use of regulatory issues.