- Site: Springfields
- IR number: 20-078
- Date: December 2020
- LC numbers: 7, 26, 28
Executive summary
Purpose of Intervention
This inspection at Springfields Fuels Limited was undertaken as part of a programme of planned inspections during 2020/21. The scope of the intervention was aligned to the ONR Decommissioning, Fuel and Waste strategy and focussed on the arrangements made under Licence Conditions (LCs) 26 and 28. Compliance with government guidance for Covid-19 was also assessed. The inspection was undertaken at the Enriched Uranium Residue Recovery Plant (EURRP) following an incident notified to ONR; this allowed a reactive unplanned inspection of LC7 arrangements to be undertaken.
Interventions Carried Out by ONR
This inspection was to confirm adequate implementation of arrangements made under the following Licence Conditions:
- LC7 Incidents on site;
- LC26 Control and Supervision of Operations;
- LC28 Examination, Inspection, Maintenance and Testing.
The inspection comprised of plant inspection, examination of procedures, document
Explanation of Judgement if Safety System Not Judged to be Adequate
Not applicable.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
The licensee was able to demonstrate from the facilities inspected; and the staff interviewed during the inspection, that it complied with the requirements of LC 28. However, shortfalls were identified in the compliance with LC 26, arrangements had been adequately made but had not been adequately implemented. ation and records and interviews with staff.
Following an incident that was notified to ONR I inspected the arrangements for compliance with LC26 and LC28 at the EURRP facility. The Licensee had already undertaken two comprehensive Root Cause Analysis (RCA) investigations for the incorrect maintenance of plant, which resulted in an active effluent leak and compromised performance of a retaining bund. Both investigations identified poor mechanical practices by insufficiently trained personnel as factors. From my own assessment of the reports and follow-up enquiries, I concur with the corrective action plans identified in the RCA reports.
Areas of improvement for compliance with LC28 have been discussed with the Licensee but it is my opinion adequate arrangements have been made and implemented for Examination, Inspection, Maintenance and Testing and hence a rating of “No formal action” is appropriate. However, LC26 compliant control and supervision was not adequately implemented at the plant for both the supervision of staff identified as having training shortfalls and in operator practices which compromised the structural integrity of the as-built bund. A regulatory issue has been raised to track the Licensee’s corrective action plan to completion and close the identified compliance gap.
The arrangements made and implemented for reporting incidents of site, LC7 were also assessed for adequacy by means of the demonstration of the Licensee to correctly notify this incident to ONR, conduct an internal investigations and produce a corrective action plan to help prevent a recurrence. It is my opinion that the arrangements are adequate.
From my on-site inspection it is my opinion that the Licensee has made and implemented adequate arrangements to comply with Government guidance on Covid-19 and has reduced the on-site risk from Covid-19 to as low as reasonably practicable.
Conclusion of Intervention
In my opinion, the Licensee's arrangements for compliance with LCs 7 and 28 are adequate. The Licensee has identified its own LC26 compliance shortfalls following the EURRP incident and an appropriate corrective action plan is in place. The incident reached the enforcement threshold of “regulatory advice”. The record of regulatory advice is documented in this report and recommends all identified corrective actions identified by the RCA reports are completed in the documented timescales. It is also my opinion the Licensee has complied with Government guidance on Covid-19 and reduced the on-site risk from Covid-19 to as low as reasonably practicable. I, therefore, conclude that this inspection identified no matters that may impact significantly on nuclear safety.