Executive summary
Date(s) of inspection: April 2024
Aim of inspection
To gain assurance that Spent Fuel Services (SFS) is ready to implement its safety case for the transfer of spent AGR fuel to, and storage of this fuel in 63C Racks. Full details in SL-2022-558-02.
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
Key findings, inspector's opinions and reasons for judgement made
Sellafield Ltd has applied to the Office for Nuclear Regulation (ONR) for agreement to implement its 63 Can Rack safety case and operational processes for the transfer of Advanced Gas-cooled Reactor (AGR) fuel from the current 20 Can Racks to 63 Can Racks and the subsequent handling and storage of laden racks. This inspection was undertaken to inform ONR’s decision on this agreement.
I, the Site Inspector for the Spent Fuel Services Operating Unit, supported by specialist inspectors, undertook the intervention which comprised inspecting against five relevant licence conditions (LCs) (LC10-Training, LC23-Operating rules, LC24-Operating instructions, LC27-Safety mechanisms, devices and circuits (SMDCs) and LC28-Examination, inspection, maintenance and testing (EIMT)). The inspection included a plant walkdown, discussion with key personnel and the sampling of documentation related to this modification.
I found that the required training packages and operational documentation are in an advanced state of readiness, subject to a final review against the safety case, noting a further change will be required to the addendum clearance certificate to take into account a pending change to a safety mechanism. SMDCs are available, were visually in an acceptable condition, had EIMT records available for their previous safety functions, and appropriate EIMT arrangements ready for their final verification prior to implementation (this equipment will have different safety requirements once the modification is implemented), once the modification proposal has completed due process. Formal training and assessments have yet to be completed, however I am satisfied that Sellafield has a plan, with appropriate management control, to deliver this ahead of commencing nuclear operations with the 63 Can racks.
I, the Site Inspector for the Spent Fuel Services Operating Unit, supported by specialist inspectors, undertook the intervention which comprised inspecting against five relevant licence conditions (LCs) (LC10-Training, LC23-Operating rules, LC24-Operating instructions, LC27-Safety mechanisms, devices and circuits (SMDCs) and LC28-Examination, inspection, maintenance and testing (EIMT)). The inspection included a plant walkdown, discussion with key personnel and the sampling of documentation related to this modification.
I found that the required training packages and operational documentation are in an advanced state of readiness, subject to a final review against the safety case, noting a further change will be required to the addendum clearance certificate to take into account a pending change to a safety mechanism. SMDCs are available, were visually in an acceptable condition, had EIMT records available for their previous safety functions, and appropriate EIMT arrangements ready for their final verification prior to implementation (this equipment will have different safety requirements once the modification is implemented), once the modification proposal has completed due process. Formal training and assessments have yet to be completed, however I am satisfied that Sellafield has a plan, with appropriate management control, to deliver this ahead of commencing nuclear operations with the 63 Can racks.
I gave regulatory advice on several matters; including that Sellafield Ltd should undertake a suitable and sufficient risk assessment and implement any identified control measures in relation to the access/egress to/from the rack handling machine.
Overall, I am satisfied that Sellafield Ltd is advanced in developing its operational arrangements to support this modification, and has the necessary resources available to complete the final requirements prior to commencing the transfer, handling and storage of the 63 Can Racks. In undertaking this modification, I am satisfied that Sellafield Ltd has complied with the LCs while developing its arrangements, and that the outcome of this readiness inspection should not prevent the granting of ONR’s agreement to this modification.
Conclusion
I am of the opinion that Sellafield Ltd has adequately implemented the arrangements made under the nuclear site licence for the five LCs inspected during this intervention, and have awarded a rating of Green for each of these. Regulatory advice was given for several matters and this advice is captured within this intervention record; the most significant being in relation to undertaking a risk assessment for the access to/egress from the rack handling machine. Overall, I am satisfied that Sellafield Ltd is advanced in developing its operational arrangements to support this modification, and has the necessary resources available to complete the final requirements prior to commencing the transfer, handling and storage of the 63 Can Racks. In my opinion the outcome of this readiness inspection should not prevent the granting of ONR’s agreement to this modification.