My interventions at Berkeley were part of a series of inspections to confirm Magnox Ltd was meeting its legal obligations arising from the conditions attached to the Berkeley nuclear site licence.
A colleague accompanied me for part of the visit to acquaint himself with the site to assist him in his work assessing the site's hazard identification and risk evaluation (HIRE) required under the Radiation (Emergency Preparedness and Public Information) Regulations 2001.
I also undertook a joint inspection with the Environment Agency's (EA) Berkeley Site Regulator.
The interventions involved consideration of Berkeley's organisational capability, control over the accumulation of radioactive waste, leakage and escape of radioactive waste, and decommissioning arrangements (licence conditions 36, 32, 34 and 35 respectively).
For the compliance interventions I used ONR guidance to judge how well Berkeley was meeting the conditions.
This intervention did not include the inspection of a safety system.
I satisfied myself that Berkeley was generally meeting relevant good practice in the management organisation at Berkeley, accumulation of radioactive waste and leakage and escape of radioactive waste. However, I found significant weaknesses in the optioneering undertaken as part of the Magnox Ltd's justification for proposed changes to two of the decommissioning programmes.
The Berkeley Closure Director and his senior managers had reviewed the management structure, which consisted of programme management on the one side (where the main nuclear safety issues are addressed) and conventional operations on the other side. On the programme management side a key function for nuclear safety was the role of design lead. I believe the job description for the Berkeley Engineering Manager centred on the interface between conventional safety and nuclear safety, with little responsibility for licence condition compliance. The Closure Director was considering separating infrastructure management and integration management, in line with the standard Magnox Ltd structure. He also told me that that a weakness had become apparent in the programme management reporting lines to the site management, important because it is the site management that is given responsibility for compliance with the law. He was looking at how to improve this.
I and the EA Site Regulator reviewed the optioneering process used to inform the proposed location of the Intermediate Level Waste (ILW) Encapsulation Plant at Berkeley. The optioneering report provided to us was 12 months old and there were significant omissions with regard to nuclear safety that undermined the conclusion of the report; for example, it did not include the opinions of a radiation protection specialist. It did not seem to have used Berkeley's site knowledge adequately. I raised this as an issue with the Deputy Closure Director. He agreed to review the optioneering taking into account the regulators' concerns. I rated this red because Berkeley had not only failed to address previous regulatory advice on this proposal, but also, it had failed to properly address the nuclear safety aspects of the proposal.
We discussed Magnox Ltd plans for dealing with cans of sludge currently stored in the vaults at Berkeley. These cans were known to be pressurised in some instances. I had previously asked for a safety case to show that all the pressurised cans can be removed from the vaults safely. Berkeley confirmed that depressurisation in the vault was being considered using high pressure water and garnet abrasive cutting techniques to cut a small hole to remove the pressure in a controlled way.
Magnox Ltd agreed to review the Encapsulation Plant location optioneering study taking account of proposed changes to ILW waste management since September 2016 and taking account of site-wide nuclear safety and radiation protection issues (for example, optimisation of on-site transport of ILW). I rated this red because requirements of the decommissioning licence condition were not addressed.
In the other areas I inspected I satisfied myself that Oldbury was adequately meeting the licence condition requirements. I discussed my findings with the Deputy Closure Director and other site managers before leaving the site.