Sellafield Limited wrote to Nuclear Directorate (ND) in September 2010, describing their strategy to implement risk reduction activities associated with Redundant Effluent and Sludge Pipework Systems (RESPS) in the First Generation Magnox Storage Pond (FGMSP) at Sellafield Site.
Sellafield Limited requested that ND Acknowledges receipt of this strategy and any regulatory hold points.
The FGMSP was constructed in the 1950’s to store, cool, and prepare Magnox fuel for reprocessing to support the UK’s nuclear electricity generation programme. Sellafield Limited have submitted an Overarching Strategy Paper (OSP) which sets out their proposals for further risk reduction activities on the FGMSP RESPS.
Assessment and inspection work carried out by ND in consideration of this request
ND has reviewed Sellafield Ltd’s OSP and considered where ND requires regulatory hold points.
Matters that arose from ND’s work and outcome of ND’s consideration
The Licensee’s submission requires a balanced consideration of the risk mitigations from carrying out the tasks compared with the increasing risks associated with the ongoing deterioration of the RESPS.
The Licensee intend to develop a generic safety case covering this work and have requested a Licence Instrument allowing them to implement a suite of plant modifications with the need for limited and targeted ND permissioning. This will enable the Licensee to deal with identified hazards more promptly while maintaining an adequate level of control.
The Licensee’s case sets out their intentions with regard to adequate risk reduction and mitigation measures including the emergency measures available in the event of unforeseen challenges to their assumptions.
The ND review has taken into account the successful performance by the Licensee on a previous RESPS project and ND is satisfied their existing arrangements are adequate to ensure risks are managed to as low as is reasonably practicable.
The review identifies two regulatory hold against the highest potential consequence work streams. This will result in further regulatory scrutiny before these specific activities commence.
ND considers that Sellafield Limited has produced its OSP in accordance with its own arrangements. The licensee’s strategy identifies how they intend managing the key nuclear safety risks associated with RESPS. Two regulatory hold points are required for two work streams, which present the greatest potential consequence within the Licensee’s submission.
ND should acknowledge receipt of the Overarching Strategy Paper allowing the work to proceed and impose two regulatory hold points.