This report covers an inspection of Magnox Ltd’s Berkeley nuclear licensed site on 15-18 June 2015. This inspection was undertaken as part of a programme of planned interventions as outlined in the Berkeley intervention plan for 2015-16. It included six compliance inspections, four of which were undertaken jointly with the Environment Agency site inspector.
During this intervention, I carried out compliance inspections on licence conditions (LC):
I examined how Berkeley used Magnox Ltd procedures to meet the LCs and Berkeley records of the outcome and discussed them with Berkeley staff.
While on site I took part in a Berkeley level 2 demonstration exercise, which was focused on the off-site response to an emergency. On-site activities were focused on driving the exercise from the Emergency Control Centre, this was done adequately, showing good management skills, capture of information and proposing actions from the information.
My inspection did not include a system inspection.
We inspected compliance with LC32, accumulation of radioactive waste on the site against ONR’s site inspection guidance. I judged implementation by Berkeley of the Magnox Ltd arrangements to be adequate. This was because Berkeley generally applied the arrangements appropriately in most of the areas we inspected. There were areas where improvements could be made, for example, in signage and bringing broken equipment back into service.
We inspected compliance with LC33, disposal of radioactive waste. In my opinion, Berkeley disposes of most of its low level waste adequately. There was room for improvement in speeding up the disposals and considering the appropriate time for sending off-site large components currently stored in the reactor buildings.
We inspected compliance with LC34, leakage and escape of radioactive material and radioactive waste. Berkeley demonstrated to me that in the main the licence condition was being met adequately in the areas we inspected. There were areas that could be improved. In particular, greater attention should be given to minimise the time radioactive waste is stored in containers in the open air. This was because it was not easy to detect leakage of water into the containers. Such leakage had the potential to damage components stored in them, which would result in additional waste management work.
I inspected compliance with LC 35, decommissioning. I found Berkeley and Magnox Ltd centrally were part way through assessing the impact of proposed changes to the planned decommissioning stages on the site. It was clear that involving Berkeley had been beneficial. At present I believe the approach had some procedural weaknesses that could mean important effects of the proposals for change will not be fully explored. However, I have confidence that there is time for Berkeley to address the weaknesses and I gave the inspection of below standard at this time, with the expectation that things will improve before I address LC 35 again.
We inspected compliance with LC 36, organisational capability. We found serious deficiencies in how Magnox Ltd was asking Berkeley to apply the arrangements. It appeared that the application of the arrangements would not result in a demonstration that LC 36 and other licence conditions would be met. In particular there was limited documentation available during the inspection to justify the safety of any proposed change, so it failed to meet LC 36(5). We sampled how the baseline met licence condition 6 and the individuals responsible for documents, records, authorities and certificates did not appear to be on the baseline and there was no provision for all the SQEPs needed to decommission the site safely on the baseline. As a result there was no clarity of how nuclear safety, which includes waste management under the licence, would be maintained. As a result I have rated this inspection as significantly below standard as significantly below standard. However this was the first of two inspections on LC 36 being undertaken to assess how Magnox Ltd is addressing LC 36 requirements. This gave Magnox Ltd the opportunity to correct deficiencies. I will consider my regulatory action following a further inspection at another Magnox site is completed by ONR’s Human and Organisational Capability specialist inspector.
I reported my findings to the Engineering manager and the acting Site Director.
From the evidence gathered during this intervention I judged Berkeley’s compliance with LCs 11, 32, 33 and 34 to be adequate in the aspects inspected. During my compliance inspections we discussed our findings with Berkeley and Berkeley proposed actions to improve safety. Some of these actions were already completed before I left the site and I am confident the others will be implemented shortly. My inspection against LC 35 indicated some potential shortfalls in the process so far, but there was the opportunity to correct them before Berkeley sends me the final milestone change proposals. The implementation of LC 36 arrangements currently do not appear to meet the requirements of LC 36 and other licence conditions. I will consult colleagues on what actions to take. This will take into account the findings of my specialist colleague when he undertakes a further LC 36 inspection at a different Magnox site.