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 plans and to carry out the planned compliance inspections
This report covers interventions at Chapelcross to address compliance inspection as follows:-
LC 6 ‘Documents, records, authorities and certificates requires the licensee to make and implement adequate arrangements to ensure that every document required, every record made, every authority, consent or approval granted and every direction or certificate issued in pursuance of the conditions attached to the licence is preserved for 30 years or such other periods as ONR may approve. For LC 6 ONR considers an IIS rating of 3 (adequate) to be appropriate. However, there are a number of areas for improvement associated with the approval under LC 6(2). The clarity of the arrangements actually approved by ONR should be increased within the licensee’s management control procedures and a number of transpose errors should be corrected to align with the approved text. ONR expects these to be addressed relatively easily by the site and these will be considered sometime in the next inspection year to confirm compliance.
LC 22 ‘Modification or experiment on existing plant’ requires the licensee to make and implement adequate arrangements to control any modification or experiment carried out on any part of existing plant or processes which may affect safety. For LC 22, ONR considers an IIS rating of 3 (adequate) to be appropriate. However, there is a need to understand the implications of an on-going management of organisational change on the implementation of the site LC 22 arrangements and to ensure the appropriate ownership is delivered to provide the necessary safety oversight and assurance to the closure director.
LC 23 ‘Operating rules’ requires the licensee produce an adequate safety case to demonstrate the safety of that operation and to identify the conditions and limits necessary in the interests of safety. Such conditions and limits shall hereinafter be referred to as operating rules. For LC 23, ONR considers an IIS rating of 3 (adequate) to be appropriate. However, the licensee is aware of the need to adequately define and identify the arrangements for conditions and limits through a graded approach and to explain this approach to the site personnel. ONR noted that the current LC 23 arrangements are not appropriate in the longer term and that a further LC 23 compliance inspection would be scheduled to monitor the licensee’s progress in this area.
LC 28 ‘Examination, inspection, maintenance and testing (EIMT)” requires the licensee to make and implement adequate arrangements for the regular and systematic EIMT of all plant which may affect safety. For LC 28, ONR considers an IIS Rating of 4 (Below Standard) to be appropriate. Shortfalls were identified in the quality of some maintenance instructions, in the defined EIMT periodicities and in the identification of plant items on job cards and actual items of plant equipment on the site. ONR will write to the licensee to require the extent of these conditions across site to be established and to secure appropriate corrective action.
The inspection established an adequate standard of compliance for LCs 6, 22 and 23. Some minor areas for improvement were identified for these LCs and further compliance inspections will be scheduled to monitor the licensee’s progress. Compliance with LC28 was judged to be below standard and ONR will issue a letter to the licensee to secure the appropriate corrective action.