Office for Nuclear Regulation

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Winfrith Pre-Licensing LC 4, 5 and CDG inspection and Board of Directors observation

Executive summary

Purpose of Intervention

Inutec Ltd has applied to ONR for a nuclear site licence (NSL) in its own right, as it has judged, and ONR agrees, that its undertakings on the Winfrith site fall under the scope of the Nuclear Installations Act 1965.  In order to assess Inutec Ltd’s suitability to hold a NSL, ONR is conducting a number of planned licence condition compliance readiness inspections. This includes inspections of Licence Conditions (LC) 4 and 5, the Carriage of Dangerous Goods (CDG) and Use of Transportable Pressure Equipment Regulations 2009 inspections, including examining their proposed arrangements for receipt and consignment of Class 7 materials and the witnessing of the Inutec Ltd Board of Directors meeting and interviews with a sample of Directors.

Interventions Carried Out by ONR

During this intervention, an ONR inspection team conducted planned readiness inspections of Licence Conditions (LC) 4 and 5, the CDG Regulations 2009 and the witnessing of the Inutec Ltd Board of Directors meeting, including interviews with a sample of Directors.

Explanation of Judgement if Safety System Not Judged to be Adequate

No safety system was inspected during this intervention.

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

I found that Inutec Ltd was able to demonstrate compliance through its written arrangements with LC 4 from the sample of arrangements inspected and the implementation of arrangements for the storage of nuclear matter on the site.  Inutec Ltd was also able to demonstrate the location of a sample of items of nuclear matter and that the corresponding record keeping was accurate.

I found that Inutec Ltd was able to demonstrate compliance through its written arrangements with LC 5 from the sample of arrangements inspected.  Inutec Ltd has incorporated references to ONR’s regulatory powers, such as the requirement not to consign nuclear matter (other than excepted matter and radioactive waste) to any place other than a relevant site in the UK other than a relevant site except with the consent of ONR, in its arrangements.

I found that Inutec Ltd was able to demonstrate compliance through its written arrangements with the CDG regulations from the sample of arrangements inspected as a tenant of Magnox Ltd but further work is required to maintain compliance if Inutec Ltd is licensed.  I identified three recommendations for improvements relating to transport arrangements. Two related to management system documentation and one to a transport emergency plan. These findings should be resolved prior to granting a site licence. A further inspection of consignment operations will be undertaken once the new procedures have had a period of implementation, most likely mid-2019. ONR will monitor progress to ensure that the identified areas of improvement are satisfactorily addressed.

I observed the Inutec Ltd Board of Directors meeting and conducted interviews with a number of the Directors.  From my observation and discussions I am content that the Board met relevant good practice.

Conclusion of Intervention

In my opinion the Licensee's arrangements made to comply with LC 4 and LC 5 are adequate from the arrangements examined, and from the location and corresponding records of a sample of items of nuclear matter checked during the inspection. 

It is my opinion that adequate arrangements are currently in place for CDG regulations but work is required to ensure continued compliance post-licensing.

It is my opinion from the observation of the Inutec Ltd Board of Directors meets ONR expectations for the purposes of gaining a NSL.