My intervention at Berkeley was to undertake planned inspections of their compliance with licence conditions relevant to: incident reporting; duly authorised and suitably qualified and experienced persons; commissioning plant; control of operations; and organisational capability. These activities are part of ONR's Decommissioning, Fuel and Waste intervention programme for Berkeley.
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.
This intervention did not include the inspection of a safety system.
I found that Berkeley was generally meeting relevant good practice in the areas I inspected when compared against ONR guidance on the licence condition under consideration.
Berkeley showed me how they met licence condition (LC) 7 on incident reporting. I noted that the categorisation of incidents followed closely ONR guidance. However, in adopting the new management control procedure, Magnox Limited did not transfer the examples previously adopted to help decide on the appropriate incident category. As a result there may be an inbuilt tendency to under report and thereby lose out on learning opportunities. I raised this concern with the Berkeley management for their consideration.
My inspection for LC 12 on duly authorised persons (DAPs) and suitably qualified and experienced persons (SQEPs) showed that Berkeley was applying relevant good practice in ensuring the individuals being appointed as DAPs and SQEPs could demonstrate both understanding and had experience in performing duties that may affect the safety of operations on the site. This included duties required during commissioning of new plant, control and supervision of operations and undertaking examination, inspection, maintenance and testing. Berkeley staff managers showed me the training programmes, interview structure and knowledge requirements for a number of DAP and SQEP roles under their management vires.
LC21, commissioning, was being applied to the intermediate level waste retrieval equipment over the vaults. I noted that the commissioning process for the vault 2 retrieval was going well and Berkeley was responding positively to the learning coming from the processes and equipment being tested. This should help to make the training of Berkeley staff in the use of the equipment and the refining the procedures into production documents successful. I concluded Berkeley were applying relevant good practice and taking opportunities for improvement in reducing risks as low as reasonably practicable.
For LC 26, control and supervision of operations, Berkeley showed me how the work discussed on commissioning was also being applied positively by managers. The learning from the commissioning was refining managers' skills to confirm the qualifications and experiences needed to control and supervise the various roles needed to transfer the waste from the vault into Ductile Cast Iron Containers, through dewatering and into long-term storage. I concluded there should be a smooth transition from commissioning to operation.
The significant change since my last LC 36 inspection was that a number of staff and contractors were due to leave the site imminently. I was able to interview one of the leavers to find out how Berkeley was managing the leaving process. He told me that he had been able to reassign his work to other staff remaining on site. Using his initiative he prepared a spreadsheet containing key information on the work he had in hand to help his successor to take over from him when such a person was appointed. The design manager post in question was not on the nuclear base line and I was concerned that it was not filled from the nuclear base line staff without due process taking place. The Site Closure Director assured me that the post would be filled appropriately. This led me to rate Berkeley as meeting the needs of the licence condition in this instance. However, the inspection took place just before some key personnel on the site were due to leave. This may have an adverse effect on Berkeley's site knowledge of what is necessary to maintain safety.
In the areas inspected, Berkeley demonstrated that the site was adequately meeting the licence condition requirements. I discussed my findings with the Closure Director's deputy, the Engineering Manager and the Site Director.