Office for Nuclear Regulation

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Operational Standards inspection - LC10, 17, 26 and 36

Executive summary

Purpose of Intervention

This inspection at the Winfrith licensed site was undertaken as part of a programme of planned inspections as outlined in the Magnox Ltd southern sites’ inspection plan for 2018/19.

Interventions Carried Out by ONR

During this inspection I examined aspects of safety management arrangements at the SGHWR decommissioning project which included inspections of arrangements made under Licence Conditions (LCs): 10 Training; 17 Management Systems; 26 Control & Supervision 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:

Whilst on site I held a meeting with a safety representative to discuss and follow-up on the issues identified in previous inspections.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable. 

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

I carried out an inspection to assess the Licensee’s implementation of LC10, 17, 26 and 36 in relation to the management arrangements for inventory limits in the SGHWR facility.  It is my opinion the safety case adequately identified the relevant limits and conditions and the format and structure of the safety case, particularly the live safety case summary, allowed the limits and conditions to be readily identified throughout these documents.  The limits and conditions were also adequately articulated into facility Local Working Instructions (LWI), thus ensuring staff following these instructions meet the requirements of the limits and conditions. 

I reviewed the training records for a sample of operational staff. I found that all such persons in the SGHWR facility had current training records against the required competences during this inspection.  I also reviewed the competence of external contractors and sought evidence as to Magnox Ltd assured themselves they were competent to perform the tasks set to them.  All appropriate evidence was available and demonstrated compliance with ONR expectations.

I reviewed the leadership and management for safety arrangements at SGHWR.  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.  SGHWR facility front line workers have regular interactions with the SGHWR and Winfrith Magnox Ltd management teams.  The arrangements for asking questions and reporting incidents and good practice go beyond that implemented elsewhere at the Magnox Ltd Winfrith or Harwell sites and implementation of this good practice should be considered across the sites.

I discussed SGHWR resources with the Authority to Operate Holder and the Human Resources Business Partners.  Based on the assurances from the Authority to Operate Holder, I was content that there are adequate resources to ensure nuclear safety at SGHWR but intend to follow up on the implementation of new arrangements for organisational capability and the reduction in the number of posts on the baseline during a future inspection.

Based on the evidence gathered during this inspection, I consider that the licensee has made and implemented adequate arrangements for complying with the inventory limits in the SGHWR facility.

Conclusion of Intervention

From the evidence gathered during this intervention, I conclude that there are no significant matters that may impact adversely on nuclear safety and that the arrangements inspected delivers the safety case intent requirements.