Office for Nuclear Regulation

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Harwell Planned Intervention

Executive summary

Purpose of intervention

This was a planned inspection at Research Sites Restoration Ltd’s (RSRL’s) Harwell site, undertaken as part of the planned intervention strategy for the Harwell site for 2014/15.

Interventions Carried Out by ONR

We (nominated site inspector and nuclear graduate) selected Licence Condition 13 (LC13) “Nuclear Safety Committee” (NSC) for inspection at this time to inform ONR’s future permissioning decisions relating to ONR Approvals of NSC Terms of Reference (ToR) and ONR Approvals of arrangements for NSC consideration of urgent safety proposals.  These ONR permissions will be required if ONR decides to relicense the RSRL Harwell and RSRL Winfrith sites to Magnox Limited (MXL).  This is because the existing ONR Approvals will “fall” on relicensing.  In the first part of this LC13 inspection we undertook a compliance inspection which considered RSRL’s current LC13 compliance arrangements and their implementation.  In the second part of this LC13 inspection we considered the LC13 arrangements that are proposed to be in place when the Harwell and Winfrith sites are relicensed to MXL.  This included consideration of the proposed ToR for the new NSCs and the proposed arrangements for NSC consideration of urgent safety proposals.  Our Integrated Intervention Strategy (IIS) rating is based only on the first part of our inspection, since only this part deals with compliance arrangements currently in place and being implemented.

We selected Licence Condition 17 (LC17) “Management Systems” (MS) for inspection at this time to inform the relicensing of the RSRL Harwell and the RSRL Winfrith sites to MXL.  This is because ONR guidance for LC17 includes the site licence condition compliance process and ONR review of licence condition compliance arrangements forms part of ONR’s licensing/ relicensing process.  In the first part of this inspection we undertook a compliance inspection which considered RSRL’s current LC17 compliance arrangements and their implementation.  In the second part of this inspection we considered two topics relevant only to relicensing.  The first topic was the licence condition compliance arrangements that will be in place when the Harwell and Winfrith sites are relicensed to MXL.  The second topic was MS changes that had occurred during shadow working.  Our IIS rating is based only on the first part of our inspection, since this part deals with compliance arrangements currently in place and being implemented.  The second part in contrast deals with compliance arrangements that will come into force when the new licences come into force or with MS changes that are part of normal MS maintenance and improvement activities and which only have special relevance since they have taken place during shadow working.

We undertook a routine review of the ONR issues database with RSRL.

We held a meeting with the RSRL Harwell safety representatives, to support their function of representing employees and receiving information on matters affecting their health, safety and welfare at work.

We held a routine meeting with RSRL’s internal regulator.

We undertook planned information gathering, including following up two incidents on the site.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable.

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

In relation to the first part of our LC13 inspection, which considered RSRL’s current LC13 compliance arrangements and their implementation, we noted that RSRL had self-identified the need to include several existing Management System documents as “Supporting Documents” in the compliance schedule for LC13.  Since this had been identified by RSRL, we did not raise an ONR issue.  We identified no issues relating to the current RSRL LC13 compliance arrangements or to their implementation.  Taking all these factors into account I (nominated site inspector) assigned an IIS rating of 3 (adequate) to LC13.

In relation to the second part of our LC13 inspection, which considered the LC13 arrangements that are proposed to be in place when the Harwell and Winfrith sites are relicensed to MXL, we made significant progress relating to the proposed Terms of Reference for the new NSCs and the proposed arrangements for NSC consideration of urgent safety proposals.  In relation to the proposed LC13 compliance schedule, we identified several inconsistencies which would mean that the proposed LC13 arrangements would not meet ONR’s LC13 requirements.  We raised an ONR issue, which needs to be resolved in a timely manner in advance of relicensing.

In relation to the first part of our LC17 inspection, which considered RSRL’s current LC17 compliance arrangements and their implementation, we considered that overall the current arrangements were of a good standard.  We inspected implementation of the arrangements by sampling the RSRL Annual Management System Review Report for 2013/14.  Following the intervention I (nominated site inspector) reviewed this report in detail and I considered it to be of a good standard.  Taking all these factors into account I (nominated site inspector) assigned an IIS rating of 2 (good standard) to LC17.

In relation to the second part of our LC17 inspection, which considered first the licence condition compliance arrangements that will be in place when the Harwell and Winfrith sites are relicensed to MXL, we identified several inconsistencies in the head document.  We raised an ONR issue, which needs to be resolved in a timely manner in advance of relicensing.  We also raised an ONR issue relating to the procedure used to change the nuclear site licence conditions compliance arrangements document.  This issue is not related to relicensing.  In this part of the LC17 inspection we also made suggestions relating to the content of a short report on management system changes during shadow working to be discussed at a readiness for relicensing review meeting on 11 March 2015.

In relation to the routine review of the ONR issues database, we considered that overall, adequate progress is being made.  I (nominated site inspector) noted that one part of an existing ONR issue (relating to Licence Condition 15 “periodic review” arrangements) and an existing ONR issue relating to the Harwell site boundary and map would need to be completed in a timely manner in advance of relicensing.

In relation to the other activities undertaken in this intervention, no key findings arose.

The intervention was performed in line with ONR’s guidance requirements (as described in our technical inspection guides) in the areas inspected.