Date(s) of inspection:
Aim of inspection
To allow the re-start of retrievals from the Pond and support the close-out of RI-8504
Subject(s) of inspection
- LC 21 – Commissioning – Rating: Not Rated
- LC 26 – Control and supervision of operations – Rating: GREEN
- LC 28 – Examination, inspection, maintenance and testing – Rating: GREEN
Key findings, inspector’s opinions and reasons for judgement made
I led a planned compliance inspection of Magnox Limited’s LC 21 (Commissioning), 26 (Control and Supervision of Operations) and 28 (Examination, Inspection, Maintenance and Testing) arrangements focussing on the re-start of pond Cobalt decommissioning activities. The inspection team comprised the nominated site inspector, a principal site inspector, and a nuclear site health and safety specialist inspector.
The inspection included an overview of the control and supervision and maintenance arrangements for the Cobalt decommissioning activity as well as a demonstration of how these arrangements reflect the safety case.
During the inspection I noted that the licensee was not treating the re-start as commissioning (LC21) hence I did not rate this licence condition.
For LC26 the licensee provided suitable evidence to demonstrate that the control and supervision of personnel was appropriate for the operational duties to be performed in the Pond. However, the licensee provided no clear plan of how the re-start activities would be performed in an orderly manner demonstrating that all requirements had been completed before the re-start could occur. Nevertheless, I judge that the LC26 (Control and Supervision of Operations) arrangements for the Cobalt pond retrievals are adequately implemented and judge a rating of Green be applied, with a L4 issue to be raised to demonstrate that the re-start of pond retrieval operations is appropriately controlled.
For LC28 I sampled several maintenance work orders that demonstrated that the equipment to be utilised during the Cobalt pond retrievals is adequately maintained and calibrated. During the inspection I also visited the Pond and witnessed the equipment in working order and housed in appropriate conditions. However, I noted that a claimed local gamma alarm was suspended due to lack of SQEP maintenance resource. The licensee however recognised that the suspension would have to be lifted prior to Cobalt retrievals recommencing. Nevertheless, I judge that the LC 28 (Examination, Inspection, Maintenance and Testing) arrangements for the Cobalt pond retrievals are adequately implemented and judge a rating of Green be applied.
During the inspection I also met with the site safety representatives and agreed to meet with them on a regular basis.
The nuclear site health and safety specialist inspector performed a review into RI-8504. Following this review and site visit they recommended the closure of the regulatory issue.
Based on the licensee’s continued maintenance of the Pond equipment removing the need to re-commission the pond retrieval equipment I did not inspect LC21 (Commissioning).
Based on my sampling and the evidence provided by the licensee, I am satisfied that the LC26 arrangements for Pond Retrievals are adequately implemented. I judge that an ONR inspection rating of Green is appropriate for this intervention.
Based on my sampling and the evidence provided by the licensee, I am satisfied that the LC28 arrangements for Pond Retrievals are adequately implemented. I judge that an ONR inspection rating of Green is appropriate for this intervention. I consider it appropriate to raise a Level 4 regulatory issue for the licensee to demonstrate that the re-start of pond retrieval operations is appropriately controlled.