This report covers an inspection of Magnox Ltd’s Oldbury nuclear licensed site from 29 June to 3 July 2015. The inspection was undertaken as part of a programme of planned interventions in the Oldbury intervention plan for 2015-16. It included six compliance inspections.
During this intervention, I carried out compliance inspections on licence conditions (LC):
I examined how Oldbury used Magnox Ltd procedures to meet the LCs and held discussions on them with Oldbury staff.
While on site I, with colleagues, observed an Oldbury level 1 demonstration exercise, which focused on the on-site response to an emergency. On-site activities were in response to the exercise events. They involved showing how Oldbury would respond if:
As part of this intervention, I also initiated my future intervention on assessment of the site’s fuel-free verification process. I started this inspections by walking the route used for moving “new fuel” up to the point where it was loaded into the fuelling machine.
My inspection did not include a safety system inspection.
I inspected compliance with LC32, accumulation of radioactive waste on the site against ONR’s site inspection guidance. I judged implementation by Oldbury of the Magnox Ltd arrangements to be of a good standard in the areas I inspected. In addition, it was clear to me that Oldbury recognised that current waste management facilities would need to be improved when greater volumes of waste are recovered in future decommissioning activities. I believe that this also demonstrates a proactive attitude. Given that Oldbury was addressing the accumulation of waste to a good standard, I rated the inspection 2 (good standard) accordingly.
I inspected compliance with LC33, disposal of radioactive waste. Most of Oldbury’s radioactive waste is classed as low level waste. In my opinion, Oldbury disposes of its low level waste adequately and I therefore rated the inspection accordingly (3 – adequate). An example discussed covered plans for two items of redundant contaminated equipment. The waste manager explained to me how Oldbury was looking at alternative ways of disposal within the cost constraints placed on the site by Magnox Ltd.
I discussed compliance with LC34, leakage and escape of radioactive material and radioactive waste. Oldbury demonstrated to me that even with older plant there was provision for containing spills of radioactive matter. I concluded that in the areas I inspected Oldbury was meeting LC34 adequately.
I inspected compliance with LC 35, decommissioning. I found Oldbury was undertaking a detailed analysis of the arrangements for the decommissioning of plant and processes which may affect safety. Oldbury was producing decommissioning programmes for each plant and considering how to divide the decommissioning into stages. The information that I saw provided me with evidence that the work is being undertaken to a good standard. I noted during the inspection that there were some changes proposed to the decommissioning of particular plan that included shipping some items to other Magnox sites and receiving other sites’ decommissioning waste for Oldbury to deal with. I reminded the site that to meet health and safety legislation, this work needed justification and an adequate safety case before the plan is implemented and the demonstration needed to address licence condition requirements as well as ultimate disposal considerations.
I inspected compliance with LC 36, organisational capability. I found that Oldbury was meeting the licence requirements to a good standard. I came to this conclusion because the site (EHSS&Q manager) had clearly undertaken a detailed assessment of the current nuclear baseline of posts needed to maintain nuclear safety and how these posts may change in the future (for example, when defuelling operations are complete). Answers to my questions provided evidence that the justification for the changes to the nuclear baseline was robust. In addition, the EHSS&Q manager had checked the need for the posts against guidance on preparing a nuclear baseline from the nuclear industry and from the ONR and also compared the baseline against Magnox Ltd’s internal requirements for meeting licence conditions and other legislation.
Oldbury is due to be free of nuclear fuel early in 2016. I started the process of verifying this. I followed the redundant new fuel route from the receipt bay up to the point where new fuel was loaded into the carousels from which it was taken into the reactor cores. I was also given a copy of Oldbury’s review of the same route. The site’s review included verification that there was no fuel in the carousels. I am satisfied that the new fuel route does not contain any reactor fuel. I noted that boxes used for new fuel shown in the Oldbury report had been moved. I intend to undertake an inspection of other parts (remainder of the fuel route) in August 2015. This work will become part of my overall inspection to confirm Oldbury is fuel free at the appropriate time.
I reported my findings to the EHSS&Q manager and the Site Director.
From the evidence gathered during this intervention I judged Oldbury’s compliance with LCs 11, 33 and 34 to be adequate in the aspects inspected. Furthermore I concluded the Oldbury demonstrated a good standard of compliance with LCs 32, 35 and 36, noting that further work was planned by Magnox Ltd to add detail to the Oldbury plant and systems’ decommissioning programmes.
With respect to the proposed changes to some aspects of the Oldbury decommissioning plans Magnox Ltd needed to prepare justification and safety cases for the changes to demonstrate compliance with the nuclear site licence conditions. The site understands these requirements.