Executive summary
Date(s) of inspection:
- November 2022
Aim of inspection
The System Based Inspection (SBI) considered the adequacy of the licensees’ fuel route safety case system and its implementation. This intervention assessed the licensee’s safety case and security case application for its fuel route. It was conducted by Mechanical Engineering, Fault Studies, Control and Instrumentation and Cyber Security and Information Assurance inspectors. They were supported by the nominated site inspector. Throughout this intervention record, “I” refers to all ONR inspectors. The security aspect of this intervention was conducted under the requirements of the Nuclear Industries Security Regulations (NISR) 2003. It considered compliance with the licensee’s Security Case and Security Operating Procedures including application of:
- physical;
- administrative;
- procedural; and
- technical security controls.
The inspection involved:
- discussions with licensee staff;
- a review of licensee safety case documents; and
- a walkdown of licensee facilities.
The inspection was informed by the Office for Nuclear Regulations technical guidance.
Subject(s) of inspection
- LC 10 - Training - Rating: GREEN
- LC 23 - Operating rules - Rating: GREEN
- LC 24 - Operating instructions - Rating: GREEN
- LC 27 - Safety mechanisms, devices and circuits - Rating: GREEN
- LC 28 - Examination, inspection, maintenance and testing - Rating: GREEN
- LC 34 - Leakage and escape of radioactive material and radioactive waste - Rating: GREEN
Key findings, inspector's opinions and reasons for judgement made
From my inspection sample, I judge that the licensee has adequately demonstrated implementation of its fuel route safety case. I identified minor areas for improvement which I do not consider prejudice nuclear safety. The Licence Condition ratings are summarised below:
- Licence Condition 10 (Training) – I sampled training records for the fuel route system engineer and individuals involved in fuel route operation, examination, inspection, maintenance and testing. I judge that training of these individuals is adequate. Hence, I assigned a Green (No formal action) rating for Licence Condition 10 compliance.
- Licence Condition 23 (Operating rules) – I sampled fuel route safety case limits and conditions. I judge the operating rules were clearly identified, adequately linked to the safety case and were understood by operators. I also sampled records showing adequate compliance with these rules. Hence, I assigned a rating of Green (No formal action) for Licence Condition 23 compliance.
- Licence Condition 24 (Operating instructions) – I sampled fuel route operating instructions. I judge the operating instructions were included in the licensees’ document management system and that they identify the necessary checks and actions required in the interests of safety. I found that these were adequately linked to the operating rules and that records showed compliance. I identified minor configuration control shortfalls with operating instructions. I captured this as a regulatory issue to provide adequate resolution oversight. This requires the licensee to adequately demonstrate configuration control of changes to operating instructions. Hence, I assigned a Green (No formal action) rating for Licence Condition 24 compliance.
- Licence Condition 27 (Safety devices, mechanisms and circuits) / Nuclear Industries Security Regulations 2003 – I sampled fuel route safety mechanisms, devices and circuits. I judge the licensee adequately demonstrated they were in good working order. I also sampled the cyber security arrangements. I identified minor shortfalls in security cases and the availability of technical details. I captured this as a regulatory issue to provide resolution oversight. This requires the licensee to adequately demonstrate the security of plant computing systems, including Computer Based Systems Important to Safety in accordance with its own arrangements. Hence, I assigned a Green (No formal action) rating for Licence Condition 27 compliance.
- Licence Condition 28 (Examination, inspection, maintenance and testing) – I sampled the fuel route examination, inspection, maintenance and testing. I judge the licensee adequately demonstrated that its associated activities are in accordance with written schemes and completed within identified timescales. I identified minor shortfalls with the licensee’s:
- Consideration of Control and Instrumentation ageing and obsolescence. I captured this as a regulatory issue to provide adequate resolution oversight. This requires the licensee to adequately demonstrate that:
- appropriate fuel route personnel receive training on the relevant company guidance;
- and that arrangements for ageing and obsolescence reviews of fuel route Control and Instrumentation equipment are implemented.
- Demonstration that hoist load trip levels ensure safety case limits are not exceeded. I captured this as a regulatory issue to provide resolution oversight. This requires the licensee to adequately demonstrate its hoist load trips prevent exceeding its limits and conditions of safe operation.
- Overall, for LC28 I judged that the licensee adequately demonstrated compliance with its arrangements. Hence, I assigned a Green (No formal action) rating for Licence Condition 28 compliance.
- Licence Condition 34 (Leakage and escape of radioactive material and radioactive waste) – I sampled the licensee’s arrangements for detecting and preventing an escape of radioactive material in, or from the fuel storage pond. I identified minor documentation shortfalls with the licensee’s demonstration of routine activities. I captured this as a regulatory issue to provide adequate resolution oversight. This requires the licensee to adequately demonstrate suitable pass/fail criteria for its pond secondary containment sump. I judge that the licensee adequately demonstrated compliance with these arrangements. Hence, I assigned a Green (No formal action) rating for Licence Condition 34 compliance.
Conclusion
Based on my sampled inspection, I conclude that the licensee has adequately demonstrated fuel route safety case understanding and implementation.