For my intervention at Oldbury I undertook planned inspections of their compliance with licence conditions relevant to: incident reporting; emergency arrangements; authorised and suitably qualified and experienced persons; control of operations; and organisational capability. These activities are part of ONR's Decommissioning, Fuel and Waste intervention programme for Oldbury during 2016-17.
I also discussed with the site how decommissioning plans were progressing. This work should result in intermediate level waste (ILW) being stored in a passively safe form either on the site or at another Magnox nuclear licensed site until a disposal route is available for the waste streams involved.
For the compliance interventions I used ONR guidance on the licence condition being considered to judge how well Oldbury was meeting the condition.
This intervention did not include the inspection of a safety system.
I satisfied myself that Oldbury was generally meeting relevant good practice in the areas I inspected when using ONR guidance on the licence condition under consideration as the benchmark.
Oldbury showed me how they had investigated a recent incident reported to ONR under Magnox Ltd licence condition (LC) 7 reporting arrangements. I noted that Oldbury had used a number of approaches to gain the most learning from the incident including consulting the appropriate experts. The investigation findings were to be made widely available to minimise a recurrence of the incident. I believe this showed that Oldbury was addressing incidents appropriately.
I witnessed aspects of an emergency exercise. I concentrated on how the access control point was managed. Of particular note was the way the access controller ensured everyone understood their role and the objectives he had set for them and the way he integrated the local ambulance service personnel into the rescue activities. As a result I gained confidence that in a real situation Oldbury would have acted appropriately.
My inspection against LC 12 on duly authorised persons (DAPs) and suitably qualified and experienced persons (SQEPs) and LC 26 on control and supervision of operations showed that Oldbury was applying relevant good practice in ensuring the individuals being appointed as SQEPs could demonstrate both understanding and experience in performing duties that may affect the safety of operations on the site. With respect to the DAPs the current system was fit for purpose but I suggested it may be appropriate to consider appointing staff with more intimate knowledge of the new plant being developed for future waste management activities. I was satisfied with Oldbury's plans to reduce the workload on DAPs and SQEPs.
For LC 36, organisational capability, I noted that a number of engineers with experience of work at other Magnox sites were being used to decommission the pond area and for other intermediate level waste management. It was not clear to me that in the pond area the proposals were taking into account the cleaner conditions present. I discussed this with the Closure Director and he told me this would be part of the responsibility of the site integrator.
Oldbury updated me on progress with ILW management in the pond area. I was shown how an area had been cleaned and used to measure the radioactivity levels in the skips. In this way it had been shown that without any cleaning 80% of them were low level waste (LLW) and could be disposed of. It may also be possible to clean some of the remaining skips to meet the LLW criteria. Oldbury also reviewed the dose calculations used on the filter being stored in the pond. They believe the original calculations may have been over estimated. To check this, the filters are to be moved to clear area and their radiation measured. I see this as a good practice as it should minimise the need for long-term storage.
In the areas I inspected I satisfied myself that Oldbury was adequately meeting the licence condition requirements. I discussed my findings with the Closure Director, his deputy and other site managers before leaving the site.
LC 12 is to ensure that only suitably qualified and experienced persons (SQEPs) perform duties which may affect safety. The safety of the plant is dependent on its design, construction, operation, maintenance and modifications made to it. Magnox Ltd. is required to implement arrangements to ensure that individuals, who perform these activities, and any other activities pertinent to safety, are SQEPs. LC12 also provides for the appointment of Duly Authorised Persons (DAPs) to control and supervise operations that may affect safety. Their appointments are subject to additional management controls covering areas such as appointment and assessment.
Oldbury used Magnox Ltd arrangements for identifying and managing their SQEPs and DAPs. What this meant in practice was that there were slight differences in terminology between the Magnox Ltd arrangements and that used in the nuclear site licence. For example the Oldbury terminology of "Appointed SQEP" is the same as a SQEP in the meaning of LC 12. Consequently, this difference did not affect the adequacy with which the licence condition was met.
My discussions at Oldbury and my interrogation of the documentation satisfied me that the arrangements apply to all personnel whose duties and associated activities may impact upon nuclear safety on the site. Where a person had duties under LC 12(1) and 12(2) the arrangements require a written job description. I checked a sample role profile and job description for a SQEP and DAP and confirmed that they specify the requisite qualifications, training and experience.
I asked about written appointment of SQEPs and was shown examples. I asked about training of SQEPs and the manager explained how he recently gave training to a number of SQEPs who required refresher sessions. The regional Business Partner also confirmed that she and her staff were looking to improve the training delivery.
This condition requires all safety related operations to be carried out under the control and supervision of suitably qualified and experienced personnel. The "operations ... which may affect safety" to which condition 26 applies includes specifically those referred to in condition 23 (operating rules) for which safety cases are required and is widely drawn to include all "operations" defined in condition 1.
Magnox Ltd had arrangements showing who the person responsible for ensuring compliance was and how LC 26 was met. The Model Management Control Procedure, OLD-MCP-001 gave an adequate definition of the terms "control" and "supervision". The Oldbury procedures identified the posts responsible for compliance with this condition.
The procedures required operations affecting safety to be identified. Posts to which persons were appointed to control and supervise operations affecting safety were identified and the suitable qualification and experience was defined for each post.
Oldbury continued to use the power generation model for defining the knowledge required by DAPs. I suggested to the Closure Director that the model was not as relevant as it used to be because in the future there will be new processes and facilities where the local manager may be more appropriate as the DAP.
Under Magnox Ltd definitions control and supervision may be exercised through work instructions and procedures supplemented by appropriate direct contact and observation.
I was satisfied that Oldbury was applying relevant good practice to how SQEPs were defined. There may be an opportunity to modernise the way DAPs are used in the future, but the existing system appeared to be adequate at present.
LC 36(1) requires Magnox Ltd to provide and maintain adequate financial and human resources and should have a nuclear baseline to provide a demonstration that it has suitable and sufficient organisational structures, staffing and competences in place to effectively and reliably carry out those activities which could impact on nuclear safety. The nuclear baseline provides a description of the currently intended staffing levels as a reference point or baseline against which Magnox Ltd can assess the potential impact on nuclear safety of proposed organisational changes, noting that it will also be affected by changes in business objectives such as reducing or increasing the time to be taken to reach a care and maintenance position on a Magnox Ltd licensed site.
LC 36(2) requires the licensee to make and implement adequate arrangements to control any change to its organisational structure or resources which may affect safety. ONR interprets this condition to relate specifically to nuclear safety although Magnox Ltd may wish to apply similar arrangements to manage changes affecting industrial safety, security, environmental matters or other parts of their business. I believe that Oldbury has such adequate arrangements.
Magnox Ltd's management of change arrangements should ensure that the nuclear safety implications of a proposed change are fully considered and that risks arising from inadequate assessment and implementation of the change are recognised and suitably controlled. The full implications of a proposed change or a series of changes are assessed prior to implementation. This assessment guards against a failure to consider all relevant factors and potential dependencies between related changes and the potential for a major change to be decomposed into a series of lesser changes which are treated independently.
Changes were classified according to nuclear safety significance. The level of assessment required was proportionate to the potential nuclear safety significance of the change.
Replacing one post holder with another post holder on a like-for-like basis need not constitute a trigger for the application of management of change arrangements as this should ordinarily be addressed through arrangements made under LC 12. However, if the post holder concerned is in a senior position with deep knowledge of the interdependencies of activities on nuclear safety LC 36 processes should be applied. Also where a number of changes are to take place in the same area or there is a consequential effect on roles and responsibilities, Magnox Ltd should apply its LC 36 arrangements.
The Magnox Ltd plans for reducing the number of posts in the company significantly had not affected Oldbury to any great extent to date. Since my last LC 36 inspections there had been changes to a number of post holders.
My discussions with Oldbury staff indicated that there was some confusion about reporting lines for staff working in the programmes. I said that it was my understanding that the programme staff's reporting line for safety was through the site integrator on behalf of the Closure Director.
I found that the application relevant good practice had been applied. Shortfalls were minor. Issues that I raised for clarification were resolved. From these findings I concluded that the site was applying LC 36 to a good standard.
I was shown the work being undertaken in the ponds. This included classifying the redundant fuel skips as either LLW or ILW. The measurement was undertaken in an area of the pond cleared of debris to reduce the background radiation present during the skip readings. To date 80% of the skips had been found to be LLW without the need for surface cleaning. Oldbury believed cleaning off the graphite on the surface of some of the ILW skips may be sufficient to re-categorise them as LLW.
Oldbury also reviewed the dose calculations used on the filter being stored in the pond. They believe the original calculations may have been over estimated. To check this, the filters are to be moved to clear area and their radiation measured. I see this as a good practice as it should minimise the need for long-term storage.
One concern that I raised was to do with Oldbury's plan to declare the whole of the pond area as being contaminated with radioactive material. The area at present is clean. I asked the Site Closure Director to consider the use of tenting to limit the area of contamination and thereby minimise the generation of secondary wastes from the pond's clean-up activities. This approach had been used successfully in the past.
I also noted the lack of welfare facilities in the pond area that made working in the area difficult for female staff.
I discussed with the safety representatives their perception of how changes on the site had been managed. They noted a number of shortfalls in the process.
I gave feedback on my inspections to the Closure Director, the Deputy Closure Director, EHSS&Q Manager and the integration manager.