Office for Nuclear Regulation

Compliance inspections of LC 8, 10, 17, 26 and 36

Executive summary

Purpose of Intervention

This inspection was undertaken as part of a programme of planned inspections as outlined in the Magnox Ltd Southern sites’ inspection plan for 2019/20.

Interventions Carried Out by ONR

During this inspection I examined the arrangements made under Licence Conditions (LCs): 10 Training; 17 Management Systems; 26 Control & Supervision and 36 Organisational Capability at the SGHWR decommissioning project. I also undertook a concurrent LC 8 Warning Notices inspection. 

The inspection followed-up and focused on a recent incident involving contractors to evaluate compliance with the LC; any learning from the incident; and to ensure the future core segmentation phase at SGHWR, which is heavily dependent on contractors, has sufficient oversight from Magnox Ltd. 

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable. 

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

I inspected the Management System (LC 17) using LC 26 arrangements to ensure a “golden thread” linked these arrangements from top-levels compliance statements to operational working instructions.  Compliance statements for Magnox Ltd Harwell/Winfrith have recently been reformatted into a Magnox Ltd Corporate template. In the template the primary implementation document for LC 26 is a Corporate process which is not implemented but directly defers to a secondary level Harwell/Winfrith specific document.  This document is not subjected to the same resource and scrutiny as primary documentation by the Magnox Ltd Corporate Centre.  The Harwell/Winfrith document at is not at the same standard as the Magnox Ltd Corporate process but the Magnox Ltd Corporate process itself does not meet relevant regulatory expectations.     This issue of the lack of a consistent and coherent Management System was raised during previous ONR enforcement relating to waste management processes but the improvement programme required to address the enforcement has yet to deliver its objectives.  Therefore it is my opinion ONR will continue to seek improvement for compliance with the requirements of LC 17.

I inspected the current arrangements for compliance with LC 26 and the improvements identified by Magnox Ltd required for these arrangements following a recent incident with a contractor.  Magnox Ltd has fully investigated the circumstances surrounding the incident where a piece of scaffolding equipment fell to the floor from height: no one was injured as a result.  Remedial actions have been identified by Site and will be incorporated into the arrangements.

I conducted an inspection of the LC 10 arrangements to assess if Magnox Ltd staff have had adequate training to safely control & supervision operations and provide adequate setting-to-work briefings for its contractors. I also determined if contractors are able to demonstrate they have had adequate training to safely preform the operations required.  The written arrangements did not match the expectations demonstrated by the custom and practice of Magnox Ltd supervisors who demonstrate a good knowledge of the required competence and industrial standards for a required task.  It is my opinion that although written arrangements require improvement, the competence of Magnox Ltd supervisors is adequate.

I assessed the arrangements made under LC 36 and was of the opinion that there has been drift of the nuclear safety baseline into a more general business baseline and functions not directly related to nuclear safety are included in the baseline and the ownership has moved from safety to HR.   Although a business baselines may be seen as good business practice it should not compromise the specific function of a nuclear safety baseline.  I inspected the nuclear safety baseline for SGHWR as it prepares for commencement of core segmentation.  During this phase the reliance on contractor provided competence and resource dominates the project.  There is currently no provision for including contractors on the baseline with the current arrangements. The inclusion of contractors on the baseline will form part of the readiness inspections for permissioning for the next phase.  It is my opinion that although the written arrangements should be improved that overall the arrangements are adequate.

I undertook a concurrent LC8 Warning Notices inspection, noting there is no risk of a criticality incident in SGHWR and any incident or emergency would probably be related to fire. It is my opinion the arrangements made for Warning Notices are adequate. 

Conclusion of Intervention

From the evidence gathered during this inspection, I conclude that there are no significant matters that may impact adversely on nuclear safety. There are ongoing issues relating to the improvements required in the Management System arrangements which are the focus of a Magnox Ltd improvement programme resulting from previous ONR enforcement but this programme has yet to deliver its objectives.