Executive summary
Date(s) of inspection:
Aim of inspection
The aim of the inspection is to determine whether the safety systems, structures and components (SSCs) associated with the Chapelcross Processing Plant (CXPP) Breakdown Cave de-planting project are able to adequately fulfil their safety duties (safety functional requirements), in line with the claims made within the safety case for the project.
The inspection will also cover progress with the issues identified with the ponds project management and Q-Pulse system open actions review.
Subject(s) of inspection
- LC10 - Training - Rating - Green
- LC23 - Operating rules - Rating - Green
- LC24 - Operating instructions - Rating - Green
- LC27 - Safety mechanisms, devices and circuits - Rating - Green
- LC28 - Examination, inspection, maintenance and testing - Rating - Green
- LC34 - Leakage and escape of radioactive material and radioactive waste - Rating - Green
Key findings, Inspector's opinions and reasons for judgement made
ONR carried out a System Based Inspection (SBI) of the Chapelcross Processing Plant (CXPP) Intermediate level Waste (ILW) Retrieval Project to judge whether the safety systems, structures and components (SSCs) and their operational implementation were adequate.
From the evidence sampled during the inspection, we judge that Magnox Ltd has adequately implemented the relevant claims in the safety case for the CXPP ILW Retrieval Project and that it demonstrated compliance with LCs 10, 23, 24, 27, 28 and 34 at CXPP.
One regulatory issue was raised for Magnox Ltd to provide ONR with its optioneering assessment and outcomes for the loading of the Cross-Site Transporter (XST) outside of CXPP (RI-10985).
ONR also noted that prior to the release of the Regulatory Hold Point for active commissioning of the ILW Retrievals from the CXPP Breakdown Cave, we would be engaging with an ONR Radiation Protection Specialist Inspector to review the Operating Instructions for cave retrievals, particularly regarding entry and egress from C4 into C2 areas. This will be followed up through routine regulatory engagement.
Overall, we judge the safety systems, structures and components (SSCs) and their operational implementation for the CXPP ILW Retrieval Project are adequate and fulfilled the requirements of the safety case.
Conclusion
Site Licence Condition 23 – Operating Rules, Rating GREEN, and Site Licence Condition 24 – Operating Instructions, Rating GREEN
Based on the evidence sampled, ONR judged that Magnox Ltd adequately implements the limits and conditions specified in the safety case and that the operating rules, and the instructions to operators are adequate. In addition to this, the OIs were being appropriately revised based on learning from the inactive commissioning of the plant.
An ONR Radiation Protection specialist inspector will review the arrangements for radiological control applied to the export of waste from the breakdown cave to ensure that radiological area designation is appropriate.
Site Licence Condition 27 – Safety Mechanisms, Devices and Circuits, Rating GREEN, and Site Licence Condition 28 – Examination, Inspection, Maintenance and Testing, Rating GREEN
The systems, structures and components necessary for safety are identified in the safety case and appropriate examination, inspection, maintenance and testing on this equipment has been completed.
Site Licence Condition 10 – Training, Rating GREEN
The training records sampled demonstrated that appropriate training is being provided and that operators have been trained on the specific activities required for the ILW Retrievals Project.
Site Licence Condition 34 – Leakage and escape of radioactive material and radioactive waste, Rating GREEN
Magnox Ltd has appropriately considered the radiological risks to operators and has implemented appropriate measures to protect the operators and prevent leakage and escape of radioactive material. This includes the use of sealed Joint European Torus (JET) bags to seal the retrieved ILW and reduce dose to operators during the waste retrieval and drum filling activities.
From the evidence sampled during the inspection, we judge that Magnox Ltd has adequately implemented the relevant claims in the safety case for the CXPP ILW Retrieval Project and that it demonstrated compliance with LCs 10, 23, 24, 27, 28 and 34 at CXPP.
One regulatory issue was raised for Magnox Ltd to provide ONR with its optioneering assessment and outcomes for the loading of the Cross-Site Transporter (XST) outside of CXPP (RI-10985).
ONR also noted that prior to the release of the Regulatory Hold Point for active commissioning of the ILW Retrievals from the CXPP Breakdown Cave, we would be engaging with an ONR Radiation Protection Specialist Inspector to review the Operating Instructions for cave retrievals, particularly regarding entry and egress from C4 into C2 areas. This will be followed up through routine regulatory engagement.
Overall, we judge the safety systems, structures and components (SSCs) and their operational implementation for the CXPP ILW Retrieval Project are adequate and fulfill the requirements of the safety case.