Office for Nuclear Regulation

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LC7, 11 and 36 Compliance Inspections; Progress and Safety Representatives Meetings

Executive summary

Purpose of intervention

This report describes an ONR intervention conducted at Magnox Ltd’s Hinkley Point A nuclear licensed site, undertaken as part of a series of routine interventions set out in the Integrated Intervention Plan for site during 2014/15.

Interventions Carried Out by ONR

The following main interventions were conducted:

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A

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

Arrangements necessary to comply with licence conditions 7 and 11 were judged to be adequate.  Arrangements were mature, robust and adequately implemented.  A small number of observations were generated and acknowledged by the licensee.

Arrangements necessary to comply with licence condition 36 were judged to be below standard.

The main reason for this judgement is centred on the fact that the licensee is required to develop and justify a nuclear baseline (A nuclear baseline describes the nuclear safety posts or roles and numbers of personnel required to deliver and maintain nuclear safety on the licensed site).  The totality and complexity of the nuclear baseline should be commensurate with the nuclear activities being conducted on the site.  Although the licensee has arrangements that appear to be adequately implemented, it is the adequacy of the arrangements that are judged to be below standard insofar as the nuclear baseline does not appear to reflect or include nuclear safety posts or roles within programmes/projects who are conducting nuclear safety activities on the licensed site. The visibility and necessity of nuclear safety posts and roles within programmes/project teams and potential inclusion within the licensee’s nuclear baseline was not demonstrated.  

It is noted that Magnox and RSRL have both contributed to the development of the Nuclear Industry Code of Practice for ‘Nuclear Baseline and the Management of Organisational Change’. This document clearly articulates expectations that if adequately implemented would satisfy the requirements necessary to comply with licence condition 36.

Satisfactory progress was observed with decommissioning projects for Fuel Element Debris retrieval, ‘Ministores’ Settling Tanks 1 to 3 relocation and Ponds.

The site has made adequate progress with delivery of actions in particularly those associated with control and supervision, the expectation being that these will be completed by the end of 2014.

Conclusion of Intervention

The licensee has been given an action to review their arrangements necessary to comply with licence condition 36. The expectation is that the review will be conducted against the ‘Nuclear Industry Code of Practice’ for Nuclear Baseline and the Management of Organisational Change as well as ONR guidance.  It will be necessary for ONR to continue to engage with the licensee on this matter. Indications suggest this could be a broader corporate Magnox Ltd issue.