This intervention record documents the planned systems inspection undertaken at the Imperial College Reactor Centre (ICRC) on the 30th June - 1st July 2014.
This systems inspection focused on ICRC's site licence conditions 23, 24, 27, 28 and 34 compliance arrangements during defueling activities. ICRC's compliance with licence condition 10 (Training) was not included as part of this system-based inspection, as it had been recently considered on 15th May 2014 as part of ONR's active commissioning readiness inspection (ONR-ICOL-IR-14-002, TRIM 2014/211243) at which ONR had given an intervention rating of 3 (adequate).
Site Licence Condition 23 - Operating rules - IIS Rating 3
There was some vagueness regarding the derivation of some ORs, with a lack of a clear 'line of sight' from the safety case, overall however I was content that appropriate ORs had been identified and were being adhered to, I therefore judge that an ISS rating of 3 (adequate) was appropriate.
Site Licence Condition 24 - Operating instructions - IIS Rating 3
Although ICRC managers exhibited an initial lack of awareness of the location of operating instructions within ICRC's documentation system, I was encouraged through witnessing the removal of a fuel element that suitable operating instructions are in place and being followed. Although in some occasions operatives were moving ahead of the task management, I judge that an IIS rating of 3 (adequate) to be appropriate.
Site Licence Condition 27 - Safety mechanisms, devices and circuits - IIS Rating 4.
Due to the out of date nature of some documentation I consider an IIS rating of 4 (below standard) to be appropriate.
Site Licence Condition 28 - Examination, inspection, maintenance and testing (EMIT) - IIS Rating 3.
Although the level of detail contained in the maintenance procedures was variable, some documents were considered to be of a good standard and it was this standard that ICRC was hoping to replicate in its future EMIT documentation. In consideration of the work currently in progress I consider an IIS rating of 3 (adequate) to be appropriate.
Site Licence Condition 34 - Leakage and escape of radioactive material and radioactive waste - IIS Rating 3
Once all the fuel has been removed only the reactor control rods and small quantities of activated material will remain and the management of these is the subject of a decommissioning safety case currently being prepared.
I consider that due to the decommissioning project being in a transitory phase, resulting in very little waste remaining and that new procedures are being developed that an IIS rating of 3 is appropriate.
The licensee was able to demonstrate that appropriate arrangements are in place to safely manage the defueling activities. Further improvements since previous inspections in the areas of loose article control and housekeeping were observed, and the transfer of a fuel element was observed to be executed efficiently and competently.
Once the defuel activities are finished, ICRC will be entering a decommissioning phase for which a new safety case and associated safety documentation are currently being developed