Office for Nuclear Regulation

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Dry fuel storage inspection

Executive summary

Purpose of intervention

This intervention was undertaken as part of ONR’s planned surveillance of regulatory permissioning activities of the EDF Energy Nuclear Generation Ltd (NGL) Sizewell B Dry Fuel Store project.  This engagement was to allow the ONR Project Inspector to evaluate progress on the development and implementation of safety case requirements for Dry Fuel Store operations.

Interventions Carried Out by ONR

Compliance inspection against Nuclear Site Licence Condition (LC) 19: Construction or Installation of New Plant, where the effectiveness of the Sizewell B Dry Fuel Store project’s Project Safety Review Group (PSRG) was evaluated; and LC 21: Commissioning, where the Testing and Commissioning Panel (T&CP) process was evaluated was carried o

ut. Explanation of Judgement if Safety System Not Judged to be Adequate

This was not a planned Safety System Inspection and no judgement was made.

Key Findings, Inspector's Opinions and Reasons for Judgements Made

I was able to satisfy myself that members of the Project Safety Review Group (PSRG) for the Dry Fuel Store project were suitably informed and knowledgeable when making decisions.  This view was based on their involvement within other Dry Fuel Store project forums, such as the Design Decision Panel and Testing and Commissioning Panel, together with other Station specific forums, such as the Sizewell B Nuclear Safety Operational Review Committee.  This PSRG has independent scrutiny through NGL’s own Independent Nuclear Assurance presence to challenge PSRG decisions and activities.  Overall, I consider the PSRG is complaint with the intent of the NGL’s arrangements, although it is still developing.  I have given an inspection rating for LC 19 of Adequate.

Based on inspection findings of the Testing and Commissioning Panel (T&CP) activities for the Fuel Building Crane I consider a rating of Good Standard against LC 21 is appropriate.  I base this rating on the quality of testing and commissioning documentation reviewed; demonstration of adequate control and supervision during observation of load testing of the Fuel building crane; and method statement, risk assessment and testing procedures being in place.  The T&CP were actively managing work and modifying their strategy to take into consideration learning gained from past experience.

Conclusion of Intervention

The Sizewell B Dry Fuel Store project is compliant with NGL’s arrangements for LC 19 and 21.  The PSRG for the Dry Fuel Store project was found to be delivering its intent based on requirements set out in NGL’s arrangements.  Evidence was provided to show how it was able to make informed decisions.  I consider the Group is developing and has the benefit of independent scrutiny through NGL’s Independent Nuclear Assurance providing appropriate challenge.  The T&CP for the Fuel Building Carne is well established and areas of good practice were identified in the development and implementation of commissioning activities based upon operational learning.

Recommendations

No regulatory actions were identified from this inspection.  I intend to monitor PSRG meeting minutes and have requested that my name is added to the meeting minute distribution list.  I also consider NGL’s arrangements for the PSRG could be strengthened with the provision of additional guidance.  I intend to discuss this finding with the ONR Civil Nuclear Reactor Programme, Operating Reactors Corporate Inspector who will take forward this issue if considered to merit regulatory attention.