ONR has now completed its assessment of the Periodic Safety Review (PSR) of the Bradwell Decommissioning Licensed Site undertaken by the nuclear site licensee, Magnox Ltd.
After careful consideration, ONR has concluded that it is appropriate to continue decommissioning operations whilst the programme of further work identified by the review is progressed. ONR has relayed its decision in writing to the Bradwell Site Director.
The decision letter affirms that ONR's view is that the periodic review is not considered complete and adequate until this further work programme is satisfactorily completed. It also confirms ONR's intention to monitor Magnox's progress in completing the work. ONR will require Magnox Ltd. to complete this programme of work to a satisfactory standard and subsequently submit a further safety submission. The further submission will need to justify the entry of the site into care and maintenance operations following the completion of the post Defueling / decommissioning phase of operations. A further submission is considered necessary due to the high level of changes to the site and to site management arrangements under care and maintenance operations.
In carrying out the PSR, the licensee is expected to review the total current safety case for the site and confirm its continued adequacy; to compare against current standards for new plant, evaluate any shortcomings and implement any reasonably practicable improvements to enhance plant safety; to identify any ageing process which may limit the safe life of the plant; and where necessary to revalidate the safety case until the next PSR, subject to the outcome of routine regulation.
For the Bradwell PSR, the above objectives have to be set in the context of a shutdown, defueled, decommissioning nuclear power station site. The periodic review process is clearly aimed towards an operating nuclear power station and for Bradwell, the scope and depth of the PSR assessment was carefully aligned to cover the relevant topics at an appropriate level of detail for the station.
The primary finding of ONR's review was the apparent difficulties involved in applying the current LC 15 (Periodic Review) arrangements to a site that is undergoing accelerated Defueling / decommissioning operations at the time that the PSR is due. The PSR process is not intended for application to a site that is undergoing the rapid changes that occur as a result of decommissioning activities. Magnox have committed to performing a joint review with ONR to identify if more suitable arrangements can be derived and implemented for LC15 submissions that are due in the post-Defueling and decommissioning phases of operations.