Date(s) of inspection:
Aim of inspection
The Sellafield Ltd arrangements for Site Licence Condition 11 require a Regulator Evaluated Demonstration Exercise (REDE) on an annual basis for nuclear safety and security.
The aim of the inspection was for the Office for Nuclear Regulation (ONR) to evaluate the emergency exercise and judge the adequacy and ability of Sellafield Ltd to put its’ emergency response arrangements into effect at any time.
Subject(s) of inspection
- LC 11 – Emergency arrangements – Rating: AMBER
Key findings, inspector’s opinions and reasons for judgement made
Purpose of Intervention
This intervention record covers the planned inspection of Exercise Enigma, a Sellafield Ltd Level 1 safety demonstration exercise. The purpose of the intervention was to evaluate the adequacy of existing arrangements to ensure compliance with Licence Condition 11.
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.
The exercise was assessed by a multi-discipline team of nine ONR inspectors located at strategic positions around the site. The inspection was completed in accordance with the following ONR guidance:NS-INSP-GD-011, Revision 7.1, March 2021 – Emergency arrangements.
Key Findings, Inspector’s Opinions and Reasons for Judgements Made
Sellafield Ltd demonstrated its emergency arrangements with an exercise involving a seismic event. The scenario was complex with multiple areas of play and provided a challenge to the responders. ONR welcomes demanding exercises as they generally provide greater learning opportunities.
The majority of exercise objectives were achieved with various associated learning opportunities. There were a number of areas of good practice with effective command and control within the Site Emergency Control Centre (SECC), prompt controlled access to the site from external responders and the implementation of timely and considered actions to protect the workers and public.
Sellafield Ltd self-identified learning opportunities associated with the reliability of communication channels and the evacuation and triage of casualties from radiologically contaminated areas.
Conclusion of Intervention
We consider that this was a challenging demonstration which identified important points for learning and consideration warranting an intervention rating of AMBER (seek improvement) for LC11. The shortfalls will be reviewed against the ONR Enforcement Management Model (EMM). Level 3 and 4 (lowest level) regulatory issues will be used for tracking and regulatory oversight of the corrective actions associated with communications and casualty management respectively.
In our opinion, the majority of exercise objectives were achieved with various associated learning opportunities.
However, we noted areas for improvement regarding:
the general reliability of communication channels available to support the emergency arrangements; and,
casualty handling in situations where the risk to life from injuries requires rapid evacuation of radiologically contaminated persons. Hence, we assigned an intervention rating of AMBER (seek improvement) for LC11.
Level 3 and 4 regulatory issues will be used for tracking and regulatory oversight of the corrective actions associated with communications and casualty management respectively.