Executive summary
Date(s) of inspection: March 2024
Aim of inspection
The aim of the inspection is to determine whether Nuclear Restoration Services (NRS) are suitably applying their modification arrangements on the site in support of the Chapelcross Processing Plant (CXPP) decommissioning project. In addition, the aim of the inspection is to determine whether the arrangements for Operating Rules and Operating Instructions are implemented appropriately for a forthcoming modification (CXPP process line removal).
Subject(s) of inspection
- LC22 - Modification or experiment on existing plant - Rating: Green
- LC23 - Operating rules - Rating: Green
- LC24 - Operating instructions - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
I led a planned compliance inspection of NRS’s LC 22 (Modification or experiment on existing plant), 23 (Operating Rules) and 24 (Operating Instructions) arrangements. I targeted the Chapelcross Processing Plant (CXPP) and the associated modification supporting decommissioning operations in the facility. The inspection team comprised the nominated site inspector and a Nuclear Graduate undergoing initial training.
For LC22, the licensee provided suitable evidence to demonstrate that they had adequate arrangements for controlling modifications at the site. Furthermore, the licensee provided evidence to demonstrate that they adequately implemented these arrangements via a Decommissioning Proposal Approval Form (DPAF) and the associated quality plans. I judge that NRS are adequately implementing the LC22 arrangements for modifications on an existing facility and I judge a rating of Green.
For LC23 and 24, I sampled the modification supporting the Process Line removal at CXPP. I viewed that NRS could adequately demonstrate how the Operating Rules were generated and then implemented appropriately in Operating Instructions and associated Quality Plans. I also witnessed Operators following one of these Operating Instructions. I judge that NRS are adequately implementing the LC23 and 24 arrangements for Operating Rules and Operating Instructions and I judge a rating of Green.
For LC22, the licensee provided suitable evidence to demonstrate that they had adequate arrangements for controlling modifications at the site. Furthermore, the licensee provided evidence to demonstrate that they adequately implemented these arrangements via a Decommissioning Proposal Approval Form (DPAF) and the associated quality plans. I judge that NRS are adequately implementing the LC22 arrangements for modifications on an existing facility and I judge a rating of Green.
For LC23 and 24, I sampled the modification supporting the Process Line removal at CXPP. I viewed that NRS could adequately demonstrate how the Operating Rules were generated and then implemented appropriately in Operating Instructions and associated Quality Plans. I also witnessed Operators following one of these Operating Instructions. I judge that NRS are adequately implementing the LC23 and 24 arrangements for Operating Rules and Operating Instructions and I judge a rating of Green.
Conclusion
I consider that the licensee has provided adequate evidence that it controls modifications appropriately and consequently based on my inspections findings I judge a rating of adequate (green) is appropriate for LC22.
Based upon my sampling and the evidence presented by the licensee, I am content that the licensee adequately identifies Operating Rules and can demonstrate implementation through the Operating Instructions. I therefore judge that, in relation to LC23 and LC24, an ONR inspection rating of adequate (green is appropriate for this intervention.