This inspection at Magnox Ltd’s Harwell licensed nuclear site was undertaken as part of a programme of planned interventions as outlined in the Magnox Ltd southern sites’ inspection plan for 2018/19.
During this intervention, I carried out an inspetion related to contact handled intermediate level waste operations including rated inspections of Licence Conditions (LCs): 10 Training; 26 Control & Supervision; 17 Management Systems and 36 Organisational Capability.
ONR has previously used System Based Inspections (SBIs) to confirm that the basic elements of a site/facility safety case as implemented in safety systems and structures are fit for purpose and that they will fulfil their safety functional requirements. The intent of this inspection was to include further elements complementing SBIs but focussing on operational standards.
The intent of the inspection was to consider key human related LCs and the Leadership and Management for Safety - ONR Safety Assessment Principals (SAPs) in an integrated way drawing on consideration of the leadership and safety culture within the facility and focusing on front-line activities. It is not however an inspection of the compliance arrangements for each of the individual licence conditions but tests the holistic implementation of these arrangements.
During the inspection, I sought to gain evidence that within the facility:
Operational practices are linked to the conditions and limits identified in the safety case (LC23); they written into the operating instructions (LC24); there is adequate supervision and control of work (LC26) and that persons conducting operations are adequately trained and authorised to do so (LC10 and LC12).
The Leaders and Managers responsible for operations have adequate ownership of operational and behavioural standards and have arrangements to monitor performance against them (LC17, SAPs MS.1 and SAPs MS.3).
The organisational structure (LC 36) and operational capability (SAPs MS.2) are adequate.
Whilst on site I held meetings with the licensee and the safety representatives to discuss and follow up on the status of actions and held meetings to discuss a number of routine matters.
The inspection comprised plant inspection, office-based examination of procedures and records and interviews with staff.
I carried out an inspection to assess the Licensee’s implementation of LC10, 17, 26 and 36 in relation to the inventory limits for in the B462.1/.6 facility. During this inspection, I reviewed the Licensee’s safety case and considered that it accurately represented the facility and identifies the associated hazards and risks. In my opinion the safety case also identified appropriate Safety Management Requirements (SMR) and the format and structure of the safety case allowed these to be readily identified. These SMRs are given a unique reference number and then articulated into facility Local Working Instructions (LWI), thus ensuring staff following these instructions meet the requirements of the SMRs.
I reviewed the training records for a sample of operational staff. I found that all such persons in the B462.1/.6 facility had current training records against all of the facility LWIs sampled during this inspection. However for the operational staff responsible for the management of the appropriate SMRs in relation to inventory movements the training records did not reflect the Suitably Qualified and Experienced Person (SQEP) status of the staff. There was an underlying assumption that if a person wrote a LWI they were SQEP and this status was not required to be record on a training record. This lead to the training record not reflecting such persons were SQEP. This matter was raised with the B462 Authority-To-Operate (ATO) holder, whom themselves identified that a review and revision of the training matrix was required to ensure it is fit-for-purpose for the continuous management of SQEP in the B462 facility. Following interviews with staff it was clear that they were SQEP in relation to the LWI that delivered the SMR.
I reviewed the operational and behavioural standards arrangements in relation to the values expected at Harwell Magnox Ltd. The Magnox Ltd value of “Target Zero” for safety was well embedded within the culture and these expectations were regularly reviewed and refreshed for all members of staff. B462 facility front line staff have regular interactions with the B462 and Harwell Magnox Ltd lead teams.
I reviewed the organisational structures and capability for the B462 in particular focussing on the staff who delivered the SMRs relating to the inventory limits for in the B462.1/.6 facility. Based on this sample, the facilities nuclear baseline and vulnerability analysis met the expectations of the ONR safety assessment principals for a capable organisation.
Based on the evidence gathered during this inspection, I consider that the licensee has made and implemented its arrangements adequately to ensure the SMRs meet the inventory limits for in the B462.1/.6 facility.
From the evidence gathered during this intervention, I conclude that there are no significant matters that may impact adversely on nuclear safety.