My intervention was held at Berkeley to undertake planned inspections of their compliance with restrictions on nuclear matter on the site, reporting incidents on the site, instructions to persons on the site and only allowing certain work to be done by duly authorised and suitably qualified persons. These activities are part of ONR’s Decommissioning, Fuel and Waste intervention programme for Berkeley.
The interventions used ONR guidance on the relevant licence condition being considered to judge how well Berkeley was meeting the condition. I shared the aspects of the ONR guidance I would be addressing in my inspections with the site prior to the interventions. Berkeley also gave me updates on current and future nuclear safety work on the site.
This intervention did not include the inspection of a safety system.
My inspection showed Berkeley was adequately meeting the licence conditions in the activities I considered in the inspections. I found some areas of good practice and some areas where improvements could be made.
Berkeley demonstrated to me how they met the aspects of ONR guidance for licence condition 4 on restrictions on nuclear matter on the site. I noted that the arrangements for transferring intermediate level waste (ILW) from other Magnox sites for long term storage at Berkeley may require revision. My inspection raised some separate questions about how the stores containing sealed radioactive sources were being managed. Berkeley agreed to address these administrative and non-safety related issues.
My inspection for licence condition 7, incidents on the site, noted a previously identified mismatch between the Magnox Ltd guidance and the ONR guidance on reporting incidents. The Magnox Ltd guidance appeared to result in under reporting to the regulator. Magnox Ltd had been made aware of this shortfall and told ONR that the differences between the two sets of guidance were to be minimised shortly. From my observations on how incidents were dealt with, I concluded that Berkeley was adequately dealing with incidents on the site, noting the need for Magnox Ltd centrally to improve the way incidents are sentenced and reported.
For licence condition 9, instructions to persons on the site, the Berkeley site licence compliance schedule primary and supporting documentation addressed general risks and hazards associated with the site for normal and emergency conditions. Whilst the associated precautions to be observed and the actions to be taken in an emergency were addressed, the documentation did not address the risks and hazards associated with the plant and its operation. However, these risks and hazards were considered each working day during the Berkeley site daily planning meeting. For this reason I came to the conclusion that Berkeley adequately gave instructions to persons on the site in regard to the risks and hazards associated with the plant on the site and its operation.
For licence condition 12, I noted staff at Berkeley appeared to be suitably qualified and experienced (SQEP) to perform duties that may affect safety. My inspection showed Berkeley was adequately addressing the requirements of licence condition 12. Berkeley needs to maintain an adequate knowledge and skills base during the organisational changes currently being undertaken and ensure opportunity is provided for Berkeley based SQEP staff to influence and maintain nuclear safety standards in the areas of waste management, decommissioning and asset and liability management
In the areas inspected, Berkeley demonstrated that the site was complying with the licence conditions addressing restrictions on nuclear matter on the site, incidents on the site, instructions to persons on the site, and the designation of duly authorised and suitably qualified persons. In the near future changes will need to be made to the licence condition arrangements reviewed by this inspection to take account of the effects of the organisation changes currently being undertaken.