Office for Nuclear Regulation

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Conduct of Inspection in support of IIS

Executive summary

Purpose of intervention

This report covers interventions in pursuit of the ONR integrated intervention strategy for Chapelcross, in particular to address regulatory issues identified as part of Inspection plan and carry out the planned Compliance inspections

Interventions Carried Out by ONR

This report covers interventions at Chapelcross A to address Compliance inspection as follows:

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A.

Key Findings, Inspector's Opinions and Reasons for Judgements Made

Only the Compliance inspections and follow–up inspections are included in the executive summary as all other interventions are for information only.

LC 10 - The purpose of the intervention was to undertake an inspection of the license arrangements and implementation under LC 10.  LC 10 “training” requires the licensee to make and implement adequate arrangements for suitable training for all those on site who have responsibility of any operation which may affect safety.  ONR considered that there were a significant number of areas for improvement within the application of the LC 10 arrangements particularly with regard to clarity and the ability of ONR to approve said arrangements.  There was also inconsistency about the application of the arrangements with regard to records, all of which gave rise to potential regulatory concern.  However, ONR noted that the site is moving to a new system using Agresso, which may change the record keeping and delivery in the next two months.  In conclusion, for Site Licence Condition 10, ‘Training’, I consider an IIS Rating of 3 (adequate) to be appropriate.  However, there a number of areas for improvement and ONR intends to undertake a further LC10 inspection later in the year to consider the position after the implementation of the new arrangements. 

LC12 - The purpose of the intervention was to undertake an inspection of the license arrangements and implementation under LC 12.  LC 12 “Duly authorised and other suitably qualified and experienced persons” requires the licensee to make and implement adequate arrangements to ensure that only suitably qualified and experienced persons perform any duties which affect the safety of operations on the site or any other duties assigned by or under these conditions or any arrangements required under these conditions.  ONR considers that there are a number of areas for improvement within the arrangements.  Additionally, ONR considers that the duly authorised roles under LC 28 outlined within the arrangements do not meet the defined criteria within the site arrangements, nor do they meet the ONR guidance.  ONR considers this to be a shortfall in the arrangements that must be addressed. In conclusion, for Site Licence Condition 12, ‘Duly authorised and other suitably qualified and experienced persons’, I consider an IIS Rating of 4 (Below Standard) to be appropriate.  This is primarily around the LC 28 DAP arrangements as the LC 28 DAPs do not appear to fulfil a DAP role as defined with the arrangements.  ONR will raise a level 4 issue on this shortfall and write to site seeking commitments as to when and how this shortfall will be addressed.

LC 26 - The purpose of the intervention was to undertake an inspection of the license arrangements and implementation under LC 26.  LC 26 “control and supervision of operations” requires the licensee to ensure that no operations are carried out which may affect safety under the control and supervision of suitably qualified and experienced persons appointed for that purpose by the licensee.  The licence condition does not require the license to make and implement adequate arrangements, but to ensure that control and supervision if undertaken appropriately and on that basis, the documentation presented to ONR does achieve that function.  However, ONR is concerned that the arrangements are not always clear and the issue of a DAP delegating duties is not an arrangements usually considered acceptable.  Chapelcross noted that and considered that the wording did not meet the actual implementation.  In conclusion, for Site Licence Condition 26, ‘Control and supervision of operation’, I consider an IIS Rating of 3 (adequate) to be appropriate.  However, there a number of areas for improvement within the arrangements. At the next LC 26 inspection, ONR intends to consider the implementation of control and supervision and how the judgements in terms of control and supervision requirements are made.

LC 36 - The purpose of the intervention was to undertake and inspection of the license arrangements and implementation under LC 36. LC36, ‘Organisational capability’, requires that the licensee provide and maintain adequate financial and human resources to ensure the safe operation of the licensed site, and make and implement arrangements to control any change to the organisation or structure which may affect safety.  ONR considered that there were a significant number of areas for improvement within the application of the LC 36 arrangements including consideration of the individuals on the baselines, which gave rise to potential regulatory concern.  However, ONR noted that the site is moving to a new MCP 36, issue 5 and as such requiring a review of the organisational baseline, when a new set of arrangements will require such a review anyway, would not be proportional regulation. In conclusion, for Site Licence Condition 36, ‘Organisational capability’, I consider an IIS Rating of 3 (adequate) to be appropriate.  However, there a number of areas for improvement and ONR intends to undertake a further LC36 inspection later in the year to consider the position after the implementation of the new arrangements.  This will probably be in January or March 2016.

Conclusion of Intervention

The inspection raised issues regarding the arrangements under LC 12 and thus a letter will be sent to site and issue placed on the issues database for closure.  The issue will need to be monitored and closed.

Additionally further LC 10 and LC 36 inspections will be carried out later in the year to consider the adequacy of the implementation of the new arrangements.