Office for Nuclear Regulation

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Harwell - Planned inspection of LC7 and 17 and reactive unplanned inspection of LC28

Executive summary

Purpose of Intervention

This inspection was undertaken as part of a planned programme of inspections for 2018/19 at the Harwell site.  The inspection focussed on the reporting culture and effective operational experience feedback.  A Reactive Unplanned LC28 Inspection was also undertaken as part of the work leading to ONR agreeing to active commissioning of the Waste Encapsulation Plant (WEP).  I also met with the Site’s Safety Representatives. 

Interventions Carried Out by ONR

During this intervention, I carried out inspection of arrangements made under licence conditions 7 (incidents on the site) and 17 (management systems)

I sought to gain evidence that:

I also carried out a project readiness inspection of LC28 (Examination, Inspection, Maintenance and Testing) as part of the active commissioning permissioning strategy for the WEP at Harwell.

I met with the Harwell Safety Representatives to discuss the Magnox Ltd Southern Sites’ issue regarding awareness of the roles and responsibilities of the safety representatives and other issues they wished to raise.

The intervention concluded with a meeting regarding updates to the management arrangements for consigning packages from site following the Novapak ONR enforcement letter.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable.

Key Findings, Inspector's Opinions and Reasons for Judgements Made

I found that the licensee was able to demonstrate compliance through its written arrangements with LC 7 and LC 17 from the sample of arrangements inspected and the staff interviewed during the inspection.

I observed the Magnox Ltd Southern Sites’ Daily Event Reporting Meeting (DERM) in which all events which have not previously discussed are categorised, rated for significance and attributed appropriate actions by members representing every facility and area of responsibility from both the Harwell and Winfrith sites this was chaired by the Regional EHSSQ Manager.  This increases the frequency of the meeting it replaces which was held twice a week to be timelier, the previous meeting was recognised as good practice and other than improving the frequency the structure of the meeting remains the same and continues to be in my opinion good practice.

The management arrangements for LC7 compliance were inspected as part of the LC17 compliance inspection.  I was provided evidence of the overarching management system arrangements for compliance with the Licence Conditions through Compliance Statements and inspected the requirements of each paragraph of LC7 (i.e. 1, 2, 3) for appropriate supporting arrangements.  In my opinion the arrangements were adequately made.

From interviews with Harwell Care and Maintenance Team relating to the implementation of the LC7 arrangements for reporting events and identifying and implementing corrective actions to help prevent recurrence, it was my opinion the arrangements for LC7 were adequately implemented.  Numerous examples of incidents raised with operational experience and feedback, both team, site, company and national were provided to me by the member of the team who had raised them.  The entire team were aware of their obligations and proactive in recording incidents and the operational learning from events.

I conducted project readiness inspection of LC28 (Examination, Inspection, Maintenance and Testing) as part of the active commissioning permissioning strategy for the WEP.  Several items of safety related equipment were selected to ensure that they were subject to Examination, Inspection, Maintenance and Testing.  The safety documentation was inspected to ensure maintenance intervals were appropriate and the competence and training of the maintenance personnel assessed on plant.  From the inspection it is my opinion that adequate arrangements are in place for the active commissioning phase of the WEP at site.   

I met with the Magnox Ltd Harwell Safety Representatives to discuss the Magnox Ltd Southern Sites’ issue regarding awareness of the roles and responsivities of the safety representatives. 

The intervention concluded with meeting regarding updates to the management arrangements for consigning packages from site following the Novapak enforcement letter. Adequate progress is being made following and if implemented the arrangements should able the Novapak to return to service, once approved by the Novapak Design Authority and returned to Magnox Ltd by LLWR as fit-for-purpose.

Conclusion of Intervention

In my opinion the Licensee's arrangements for compliance with LC 7 and 17 were adequate from the sample of arrangements inspected and the staff interviewed during the inspection.  The arrangements for LC 28 for the active commissioning of the WEP were also found to be adequate.  I therefore concluded that there are no matters that may impact significantly on nuclear safety and that could affect our agreement to actively commission the WEP on site.