News from Mannin Branch Celtic League:‘IAEA Do take part in monitoring say ONR’I?ve received a very comprehensive reply from the Office for Nuclear Regulation (ONR) to our query following the BBC Panorama programme on Sellafield safety deficiencies (link): (voir le site) ONR response is comprehensive running to five pages and was in pdf so I have converted it to Word and extracted the main points ? I should stress that any textual errors are down to me.The main issue the programme raised was over staffing this is what ONR say:?In relation to the broader concept of minimum staffing, it may be helpful to offer some further context on this issue from a regulatory perspective.?Nuclear operators are required to identify minimum staffing levels that are needed to undertake operations safely. The Office for Nuclear Regulation (ONR) defines such levels in terms of the minimum number of qualified workers who must be present to ensure the safe operation of the facility and an adequate emergency response capability. In practice, this means defining a number of roles in each nuclear facility and support facility that is required to maintain safety. These roles are filled by suitably qualified and experienced persons who are trained and assessed against the specifications of the role. The exact number varies depending on the specific processes and plant.At Sellafield, in the event that these levels will not be met, prompt action needs to be taken by the operator to either meet those levels (e.g. by bringing in staff from other facilities) or reduce (or cease) operations to an appropriate level that reflects the available staffing.If these actions are not taken and Sellafield went on to actually operate the plant or process below its minimum level, then this is something they must report to us. In such cases we are particularly interested in the actions taken to address the situation. The so-called ?breaches? of minimum manning referred to by Panorama are therefore in practice more a measure of the site?s efficiency than of safety. It becomes a safety concern if they go ahead and operate the facility without enough staff.?We asked specific questions:On so called ?whistleblowers? ONR said:?ONR is a ?prescribed person? under UK whistleblowing legislation – if an employee believes that health and safety law is or has been breached, or a criminal offence on any matter is being committed on a nuclear site, this can be reported to ONR. This can be done in two ways, either by completing an online form (via the ?contact ONR? section through the ONR website (voir le site) ) or via one of the ONR inspectors who have regular discussions with staff during site visits.?On our reference to ONR saying the site faced ?unique challenges? – ONR said:?The unique challenges referred to at Sellafield are a reference to the considerable amount of work that is required to clean up historic legacy facilities and decommission older plants. For this reason Sellafield remains ONR?s highest regulatory priority and, as a result of the delivery of our strategy, the site is becoming safer every day as waste is retrieved from legacy facilities and put into modern standards storage. Some of the issues covered in the documentary were related to these historic plants, but the alleged shortcomings do not signify an imminent safety risk to workers or the public. ONR is clear that if we considered any plant to be unsafe we would shut it down or demand action to reduce that risk and return it to safety?We asked would they consider modifying quarterly reporting criteria – ONR said:?Under arrangements made to comply with legal and other requirements, ONR regularly receives notifications and reports of incidents and events occurring on nuclear sites. The only such event that featured in the Panorama programme was a 2013 contamination incident at the Waste Vitrification Plant at Sellafield.No workers were affected during this event and no contamination left the building.Consequently the event did not meet Ministerial Reporting Criteria as defined within theNuclear Installations (Dangerous Occurrences) Regulations 1965 and ONR guidance.Following this event, ONR served Sellafield Ltd with a legal Improvement Notice which ultimately made the Waste Vitrification Plant more resilient and also led to improvements in electrical infrastructure.We do not have any plans to revise our criteria as a result of the documentary and we are not aware of any proposals to amend the national legislation which covers Ministerial Reporting Criteria.?We asked about IAEA inspections ? ONR said the IAEA did have a role in monitoring:?The IAEA Integrated Regulatory Review Service (IRRS) assists member states to enhance the organisation and performance of national nuclear safety regulatory bodies. IRRS is a peer review service conducted by a team of international experts with experience directly relevant to the areas of evaluation. The review is an objective comparison of national nuclear regulation with international guidelines. The most recent IRRS Mission to the UK was in 2013 and, although specifically examining ONR?s regulation against international standards, included two visits to the Sellafield site to witness our regulatory processes first hand.The final report from the 2013 IAEA Integrated Regulatory Review Service (IRRS) mission, and information from other IAEA regulatory reviews, is available via our website (voir le site) 2016 the UK hosted a mission of the IAEA?s International Physical Protection Advisory Service (IPPAS) which provides peer advice on implementing international instruments and Agency guidance on the protection of nuclear and other radioactive material and associated facilities. The mission, which concluded that the UK?s nuclear security regime is robust, included a visit to the Sellafield site.?Finally to our query about the Civil Nuclear Constabulary ONR was less forthcoming saying:?As you have suggested in your question, the overall establishment of the Civil Nuclear Constabulary is a matter for the Civil Nuclear Police Authority. However, ONR has regular engagement with government departments to ensure nuclear material and facilities are appropriately protected.?We are grateful to ONR for providing a speedy and comprehensive response.BERNARD MOFFATTPublic Relations Officer Mannin BranchIssued by: The Mannin branch of the Celtic League.30/09/16