This inspection on the Magnox Ltd Harwell licensed site was part of a programme of planned interventions as outlined the Magnox Ltd southern sites’ inspection plan for 2019/20. The scope of the inspection is aligned to the ONR Decommissioning, Fuel and Waste sub-division strategy and focussed on the effective management of radioactive waste. The inspection was carried out jointly with the Environment Agency.
During this inspection, I examined the arrangements made under Licence Conditions (LCs): LC 32 Accumulation of radioactive waste; LC 33 Disposal of radioactive waste; and LC 34 Leakage and escape of radioactive material and radioactive waste.
I sought to gain evidence that:
I found that the licensee was able to demonstrate compliance through its procedures and written arrangements with LC 33 and LC 34. However in my opinion the Licensee's arrangements for compliance with LC 32 were not adequate.
The licensee was unable to provide a clear link between the local working instructions for LC 32 and the Magnox Ltd management arrangements for Harwell. The licensee is still transitioning from its previous management system under RSRL to the Magnox Ltd Corporate management system and at the time of the inspection were unable to provide a clear resourced and committed plan to achieve compliance; this work is potentially creating a backlog in which Local Working Instructions being created, to reflect relevant good practice and operational learning, are not being incorporated into the management system in a timely fashion and creating additional compliance issues.
Despite the shortcomings in documented arrangements, a physical inspection of the arrangements as implemented appeared to be adequate. The personnel interviewed were open, knowledgeable and competent in their areas. The physical walk-downs showed a high-level of management control over operations: housekeeping, access control and signage.
From previous inspections conducted during commissioning of the Waste Encapsulation Plant at Harwell, effective radioactive waste management safety cases were assessed as being adequate, as was the proposed waste package design which was aligned with relevant good practice.
The licensee was able to demonstrate that it minimises waste accumulations on site, from operations and decommissioning activities, it adopts the established hierarchy for waste based on a project waste management plan which defines the route and the appropriate waste acceptance certification for disposal. The site also has an up-to-date Radioactive Waste Management Case which has superseded the previous Integrated Waste Strategy.
In my opinion the licensee's arrangements for compliance with LC 33 and 34 were adequate from the arrangements examined and the plant inspected. In my opinion the Licensee's arrangements for compliance with LC 32 were not adequate from a managerial compliance rather than a direct safety perspective. A plan for the return to compliance was requested in writing from the Site Closure Director. I conclude that there are no matters that may impact significantly on nuclear safety.