This inspection was carried out at the Bradwell nuclear licensed site as part of a wider ONR assessment of Magnox Ltd.'s preparations to transition the Bradwell site into long term care & maintenance (C&M).
ONR undertakes regulatory interactions with Magnox Ltd. in line with a strategy defined by the Decommissioning Fuel and Waste (DFW) 2017-2020 which contains a number of strategic objectives and milestones relating to key pieces of regulatory work. One of the milestones within the DFW strategy relates to the permissioning of the transition of the Magnox Ltd. Bradwell site into long-term C&M.
Key regulatory activities undertaken - The key regulatory activities undertaken during the inspection were based around plant walk-downs and meetings focussed on:
The key regulatory findings are structured around the ONR specialisms participating in the inspection; meetings attended and plant visits undertaken.
The discussions and plant walk-downs identified that whilst Magnox Ltd. have well established asbestos management arrangements, there are eight topic areas where improvements are required to ensure that the arrangements to manage ACMs leading to and during C&M are effective for the risk presented by the asbestos inventory to remain on site.
The areas for improvement include improving the quality of the asbestos register; the basis for ACM condition monitoring intervals; how radiological protection arrangements influence asbestos management; developing assurance arrangements for entry into C&M and provision of information to workers that may disturb ACMs.
The initial participation in this inspection of the radiation protection (RP) specialist inspector was familiarisation of the Bradwell site and to hold discussions with Magnox Ltd RP staff to inform assessment of the RP arrangements for the C&M entry safety case. However, the main participation of the ONR RP specialist inspector was in support of the Conventional Health & Safety inspection.
This was useful interaction and discussion on some key aspects concerning the management and arrangements for radiation protection relevant for entry into, and during C&M. A number of questions have been raised requiring further clarification from Magnox Ltd.
The ONR radiation protection specialist inspector has found the Magnox Ltd safety justification to not clean and remove asbestos - solely on the grounds of radiological protection - has not been proven for some ACMs within the reactor safestores. As such, Magnox Ltd do not have a holistic position of risk and ALARP concerning radiation protection and management of asbestos going into C&M for a number of reactor safestore areas.
The purpose of the ONR Leadership and Management for Safety (LMfS) element of the inspection was to:
It was considered that Bradwell are consolidating a good information package that will be self-standing and useful during both C&M and Decommissioning. However it was considered that more consideration should be given to site re-entry and setting to work.
The LMfS inspector was pleased to see how the arrangements were developing and proving to be a useful proportionate approach to managing organisational changes at lower hazard sites. Advice was provided on including the vulnerability analysis to ensure an adequate risk assessment of the organisational capability is managed. The Sizewell and Bradwell representatives accepted the advice provided.
For the reasons below site were asked to take corrective actions to address the findings of the inspection:
All observations made were accepted by the site management team and corporate Magnox Ltd personnel present. The Site Closure Director also provided a personal commitment to ensure the findings were addressed and Magnox Ltd. has undertaken to write to ONR providing a formal commitment to act on the improvement areas identified, and develop an action plan to implement the necessary actions by 31st December 2017.
Notwithstanding these observations, it is evident that Magnox Ltd. has completed all actions arising from the June 2016 asbestos management intervention.