This intervention was undertaken on 7 January 2016 at the Pile Fuel Storage Pond (PFSP) on Sellafield Limited’s (SL’s) Sellafield nuclear licensed site in Cumbria.
The purpose of this intervention was to assess SL’s implementation of its Licence Condition (LC) 22 arrangements and gain assurance that PFSP is in a state of operational readiness to safely export the metal fuel inventory from the pond to the Fuel Handling Plant (FHP) for safe interim storage, pending a long term disposal solution becoming available. This intervention supports the ONR permissioning decision on commencement of metal fuel exports and is consistent with the ONR strategy to accelerate the risk and hazard reduction in the Sellafield legacy ponds.
The primary focus of this intervention was to inspect the PFSP’s plant, processes and people to assess its readiness to safely export the metal fuel. The readiness inspection was undertaken against LC 22 ‘Modification or experiment on existing plant’, which requires the licensee to make and implement adequate arrangements to control any modification or experiment carried out on any part of the existing plant or processes which may affect safety.
We completed the inspection (which comprised desktop-based discussions and a plant inspection) against LC 22 in accordance with ONR guidance Technical Inspection Guide (TIG) NS-INSP-GD-022, LC22: Modification or Experiment on Existing Plant, Revision 3, December 2014.
N/A – This was not a safety system inspection.
Based on the evidence sampled during this intervention, we have given an integrated intervention strategy (IIS) rating of 3, ‘Adequate’, for SL’s implementation of its LC 22 arrangements. With respect to TIG NS-INSP-GD-022, SL demonstrated:
We judge a higher rating was not appropriate because SL still needs to complete its specified programme of work to be in a state of readiness to commence export of the PFSP metal fuel.
Based upon our sample and the evidence gathered, we judge that SL’s implementation of its LC22 arrangements related to Plant Modification Proposal (PMP) process is adequate. In relation to the state of readiness of the proposed modification, we identified that SL needs to complete its specified programme of work to be in a state of readiness to commence active commissioning. As a result, we were unable to gather sufficient evidence on certain aspects that are judged relevant to the permissioning decision at the time of the inspection.
We have clarified the evidence that SL will need to provide to us to inform our permissioning decision and this relates to completion of key documentation and operator trials, which will be confirmed via the SL internal regulator.