This intervention was undertaken on 17 March 2016 at the First Generation Magnox Storage Pond (FGMSP) on the Sellafield nuclear licensed site in Cumbria. The purpose of this intervention was to assess Sellafield Ltd’s (SL) implementation of its Licence Condition (LC) 22 arrangements and gain assurance that FGMSP is in a state of operational readiness to safely commence active commissioning and operation of the FGMSP export route. This project facilitates the export of FGMSP legacy fuel 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 these operations 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 FGMSP’s plant, processes and people to assess its readiness to safely commence active commissioning and operation of the FGMSP export route. 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 facility 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:
That procedures and instructions have been assessed as part of the implementation of the modification and that plant simulations and the use of 3D modelling has usefully informed this.
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 active commissioning and operation of the FGMSP export route. We note that this requires a range of work to be undertaken against challenging timescales and have emphasised that whilst work should be done in a timely way, care is a required to ensure that standards are not compromised.
Based on our findings, we judge that SL’s implementation of its LC22 arrangements related to the Plant Modification Proposal (PMP) process is adequate. Based on the evidence sampled, no shortfalls were identified that would prevent permission being granted for commencing active commissioning and operation of the FGMSP export route.
In relation to the state of readiness of the proposed modification, SL needs to complete its specified programme of work, which SL acknowledged. 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 training, which will be confirmed via the SL internal regulator.