My intervention was held at Berkeley to undertake planned inspections of their compliance with licence conditions (LCs) relevant to site plans, designs and specifications (LC 16), modifications on existing plant (LC 22), control and supervision of operations (LC 26), decommissioning (LC 35) and organisational capability (LC 36). I represented ONR at the Oldbury and Berkeley Site Stakeholder Group meetings. These activities are part of ONR’s Decommissioning, Fuel and Waste intervention programme for Berkeley.
I also undertook a joint inspection with the Environment Agency of the Berkeley Vault 2 plant active commissioning.
For the compliance interventions I used ONR guidance on the 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 site personnel prior to the interventions.
I discussed with Berkeley and the Environment Agency the findings so far from the active commissioning of the Vault 2 intermediate level waste retrievals.
This intervention did not include the inspection of a safety system.
My inspection showed that on average 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 LC 16 on site plans and the schedule of buildings and plant which might affect safety. I noted that some updating could be made to the schedule to reflect recently completed waste management operations and proposed new structures for future activities. Berkeley had already noted the need to reissue the site plan. I rated the inspection as showing a good nuclear safety standard. I also looked for a golden thread from the site plan to the schedule of buildings and through to the maintenance schedules and found this to be adequate.
My inspection for LC 22, modifications on existing plant, showed that Berkeley was implementing the modifications to enable retrieval of waste from the vaults in a safe controlled manner. The unexpected findings in the first few scoops of waste during assay had been covered by the safety case and the delay this caused had been used to implement further modifications to equipment to improve the effectiveness of future assay work and the efficiency of operations. I considered this to be all part of active commissioning process. I concluded that Berkeley was again showing a good nuclear safety standard.
My joint inspection with the Environment Agency was carried out as part of the LC 22 inspection on the work undertaken on the active commissioning of the vault retrieval equipment. We were shown how the waste could be moved around the vault to make it easier to retrieve by the petal grab. The contractor also showed us videos of the grab being used and the sorting of materials on the tray after assay and finally being tipped into the Ductile Cast Iron Container. We also discussed the assay findings and Magnox Ltd indicated how they had modified the retrieval equipment to enhance the accuracy of the measurements further at little extra cost.
For LC 26, control and supervision of operations, Berkeley showed me how the site was preparing for the waste retrievals becoming a routine operation by ensuring out of hours operations were appropriately supervised and controlled by shift lead engineers who had demonstrated their ability to undertake the role. Discussions with other site staff and contract staff controlling and supervising the active commissioning of the equipment gave me confidence that LC 26 was met adequately.
For LC 35, I noted that the current decommissioning programme controlled by Berkeley personnel under the old management structure was working well and the fundamental requirements of LC 35 decommissioning were being met. There are procedural weaknesses in the management of changes to the site decommissioning programme in that there is not a clear alignment between the safety case documentation necessary to justify the revised decommissioning strategy and site programme. This situation does not seem to have improved since the last time I inspected against LC 35 and so I rated Magnox Ltd’s approach to decommissioning at Berkeley as below standard.
The significant change addressed by my LC 36 inspection was the preparations for the next phase of Magnox Ltd management structural changes at the site. Magnox Ltd was not able to provide an adequate justification for the proposed new organisational structure and nuclear baseline and has not conducted an adequate vulnerability analysis of foreseeable changes to posts important to demonstrating compliance with the requirements of the licence conditions. This led me to rate the site below standard on LC 36 controlling organisational capability.
In the areas inspected, Berkeley demonstrated that the site was complying with the licence conditions addressing site plans, modifications on existing plant and control and supervision of operations. There was the potential to improve the management of organisational change and the demonstration that the proposed changes to decommissioning plans would be justified from a safety perspective. I discussed these issues with the new Closure Director and he gave me confidence that he will address the shortfalls in ONR expectations that I found.