This inspection was one of a series of planned inspections at the Chapelcross (CHX) site for 2018/19.
Three planned Licence Condition (LC) Compliance Inspections were carried out of arrangements made under LC10 (Training); LC12 (Duly authorised and other suitably qualified and experienced persons); and LC14 (Safety Documentation). In addition we undertook a Systems Based Inspection (SBI) related to Fire Protection on site. Finally we met with the site’s Safety Representatives.
My inspections for LC10 and LC12 found that CHX was adequately implementing its arrangements for training and appointing Duly Authorised and Suitably Qualified and Experienced Persons. However, I noted that the new corporate standard S-743, which replaces CHX standard MCP-11, removes the requirement for Shift Leaders to be DAP. The impact of this needs to be better understood and this is being followed-up by ONR.
My LC14 inspection found that CHX was adequately implementing its arrangements in the areas inspected. However, I noted that the Corporate Standard S-259 had been used as the basis for the removal of safety mechanisms from the safety case, with no statement on whether they should be retained as ALARP measures. Application of S-259 in this manner is not consistent with the ALARP principle. S-259 is the focus of ongoing engagement with Magnox Ltd.
The SBI, focused on Fire Protection, found that CHX generally fulfils the requirements of its safety case. ONR noted some improvements to be made in flammable waste lay-down areas to reduce fire loading thereby reducing risks to nuclear safety related plant in the case of a fire, however generally the removal of waste in the buildings inspected had progressed reasonably well since the last site inspection.
No formal action is required by CHX in relation to LC10, LC12, LC14 and the Fire Protection System.
The licensee has agreed to make improvements in the areas identified through the course of the inspection and these will be followed up through routine interactions.