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
This report covers interventions at Chapelcross to address Compliance inspection as follows:
Safety case informed system based inspection on System 4.4 nuclear lifting and handling.
The System Based Inspection of System 4.4 nuclear lifting and handling for mechanical engineering systems was judged to be implemented adequately and in accordance with the requirements of the safety cases.
Only the Compliance inspections and follow-up inspections are included in the executive summary as all other interventions are for information only.
LC 8 - The purpose of the intervention was to undertake an inspection of the license arrangements and implementation under LC 8. LC 8 'Warning notices'' requires the licensee to ensure that suitable and sufficient notices are kept on site for the purposes of informing persons. ONR noted that the site record of the location of warning signs did not accord with the situation within the facilities and owing to the significance of the deviation of the recorded position from the reality and the failure of the site to comply with their own arrangements I have rated this condition amber as the specific legal requirements are not met, but there is no overall impact to nuclear safety. As such an issue will be raised on the site to confirm the accuracy of the records with the reality on the facilities.
LC 9 - The purpose of the intervention was to undertake an inspection of the license arrangements and implementation under LC 9. LC 9 'Instructions to person on site' requires the licensee to ensure the every person authorised to be on the site receives adequate instruction, ONR noted minor inconsistency in application of the sites own arrangements and also noted that the site arrangements do not call for consideration of refresher training with regard to site instructions and given the nature of the workforce on site this would appear to be a gap that needs to be considered. Overall, I consider an inspection rating of green to be appropriate.
I consider that the licensee demonstrated during the System Based Inspection from the samples taken adequate compliance with the requirements of the Cartridge Cooling Pond 50T crane and Heat Exchanger deplanting project lifting safety cases from a mechanical engineering perspective.
CXA uses Quality Plans to show compliance with LC 23 for the Heat Exchanger deplanting project. ONR was not satisfied that adequate compliance was demonstrated for deplanting Heat Exchangers 11-14 as the Quality Plans were not in place. However, taking in to consideration the explanations provided, the evidence of previous quality plans meeting expectations and the initial stages of deplanting for Heat Exchangers 11-14, along with the commitment given by CXA to put Quality Plan arrangements in place immediately, it was judged appropriate for the work to continue.
Overall, on balance, I award an inspection rating of green for the System Based Inspection of System 4.4 nuclear lifting and handling for mechanical engineering based on the inspection findings overall. I consider the LC 8 inspection to be amber and the LC 9 inspection to be green.
The inspection raised two issues, one regarding LC 8 implementation of the site arrangements and one regarding LC 23 quality plans providing evidence of compliance for limits and conditions necessary in the interests of safety for the heat exchanger deplanting. These will be communicated to site.