I undertook inspections of Magnox Ltd's Berkeley nuclear licensed site as part of the planned intervention strategy for the Decommissioning, Fuel and Waste Programme of the Office for Nuclear Regulation (ONR). Berkeley updated me on progress with intermediate level waste (ILW) decommissioning activities on the site.
I met two of the Berkeley Safety Representative and attended the Berkeley Site Stakeholder Group Meeting.
I sampled how the Magnox Ltd implements its arrangements at Berkeley for incidents on sites (licence condition 7 (LC7)), emergency arrangements (LC11), management systems (LC17), examination, inspection, maintenance and testing (LC28), and decommissioning (LC35) were applied to activities on the site. I discussed the Berkeley organisational capability structure related to nuclear safety (LC36).
I did not undertake an inspection of a safety system during this visit to the site.
Berkeley hadn't had a significant incident for some time. My LC7 compliance inspection indicated that a healthy number of anomalies were reported. This is good as such reports are used to improve safety on the site and other sites. Berkeley undertook a detailed breakdown of keywords used to categorise the anomalies. I also noted that there appeared to be a minor difference in the Magnox Ltd system and the way the International Event Scale defined incidents. Berkeley agreed to look into this.
For my LC11 emergency arrangements inspection, I discussed the Berkeley safety case on the nuclear risk from the site. Berkeley believed this had shown that the off-site risk from the site had reduced significantly. However more fuel than expected had been found mixed in with the fuel element debris and as a result the safety case had been reviewed and modified to reflect actual conditions. The revised safety case will form part of the assessment undertaken by ONR to confirm it should be possible to remove the off-site emergency planning requirements placed on the local councils around the nuclear licensed site. I asked Berkeley how it was preparing staff for the resultant changes to the on-site new emergency scheme. I gained confidence that Berkeley would be in a position to implement the new scheme and demonstrate this to me later in 2017.
I started my inspection of LC17 by seeing how Berkeley management systems address quality management arrangements for programme working in areas dealing with intermediate level waste (ILW). The document referenced as the management system appeared to be no longer available on the Magnox Ltd intranet. It was also not clear to me how the Berkeley Closure Director controlled the quality and safety of work undertaken on the site by workers on the decommissioning and waste management programmes. I asked Berkeley to clarify this for me by asking the programme managers which management systems they used to comply with LC17.
I found that Berkeley was managing its maintenance schedule appropriately.
During a joint meeting with the Environment Agency, Berkeley and me it became clear that the time taken for Radioactive Waste Management Ltd to conclude that an Intermediate Level Waste (ILW) stream package can be disposed of was taking a lot longer than allowed in the Magnox Ltd Berkeley decommissioning programme. This could cause significant delays to the start of packaging waste in concrete boxes at Berkeley.
I noted during my discussions with Berkeley on the core baseline posts and programme baseline posts that the posts relevant to meeting the nuclear site licence had become unclear. Also the actual content of a post that related to meeting the nuclear site licence was not measured. It appeared to me that the majority of the posts relevant to nuclear safety were in the programme work streams as this was where ILW was being made passively safe before the Berkeley site goes into its care and maintenance phase. We agreed that the posts needed to maintain the nuclear site licence conditions needed to be clarified.
I found nothing to indicate that nuclear safety was adversely affected by the lack of clarity on how the programmes meet the licence conditions from the information Berkeley gave me and evidence I gathered during this inspection. However it is important that Magnox Ltd can demonstrate how it meets the licence conditions, so I asked Berkeley to clarify how the Magnox Ltd documentation on programmes met the licence conditions concerned with management systems, decommissioning and organisational capability at Berkeley. I agreed with Berkeley management that this clarification is achieved before my inspection at the site during April 2017.