- Site: Harwell
- Inspection ID: 50281
- Date: August 2022
- LC numbers: 22, 23, 24
Executive summary
Purpose of inspection
The aim of this Operating Rules themed inspection was to confirm the Magnox Ltd (ML) Southern Harwell Site arrangements for implementation of Operating Rules (ORs), how they are introduced into the operational safety case though controlled modification (LC22) and that they are constructed and implemented into operational documentation in accordance with relevant good practice (LC23 and LC24).
Subject(s) of inspection
LC22 – Modification or experiment on existing plant (Rating – Green)
LC23 – Operating rules (Rating – Green)
LC24 – Operating instructions (Rating – Green)
Key findings
During this intervention, I carried out a compliance inspection against the following licence conditions: LC22 Modifications or experiment on existing plant; LC23 Operating Rules and LC24 Operating Instructions. I sought to gain evidence that arrangements have been made and implemented under the above LC’s for the ongoing activities being undertaken on the site. This was a themed inspection focussed on the arrangements for the identification of Operating Rules, how the operationalsafety case is modified though controlled modification(LC22) to modify or introduce new operating rules, that the Operating Rules are constructedand implemented into operational documentation in accordance with relevant good practice (LC23) and that safety requirements have been adequately transposed into operating instructions (LC24).
I sampled the arrangements for LC22 and concluded they were adequate and aligned with ONR guidance. I sampled from modifications that introduced or modified operating rules and concluded that arrangements had been adequately implemented with no significant regulatory concerns.
From the arrangements, operating instructions and documentation sampled, I found that the licensee’s arrangements for LC23 were adequate and principally aligned with ONR guidance. The inspection identified a minor opportunity for improvement regarding specification of the underlying safety functional requirements of Operating Rules.
I sampled the arrangements for LC24 and concluded they were adequate and aligned with ONR guidance. I sampled operating instructions to confirm Operating Rules had been appropriately cascaded from the safety case into working level documentation. The inspection identified an opportunity for improvement regarding informationto operators to align with relevant good practice guidance.
Judgements made
I sampled the implementation of arrangements for LC22 and I identified no matters of regulatory concern. I consider a rating of GREEN, “No formal action” against LC22 to be appropriate.
From the arrangements, operating instructions and documentation sampled, I found that the licensee’s arrangements for LC23 were adequate and principally aligned with ONR guidance. The inspection identified minor opportunities for improvement regarding the guidance to authors of operating rules to reflect good practice by identifying the safety function of the operating rule. No significant observations were made against the arrangements and therefore consider a rating of GREEN, “No formal action” against LC23 to be appropriate.
From the arrangements, operating instructions and documentation sampled, I found that the licensee’s arrangements for LC24 were adequate and principally aligned with ONR guidance. The inspection identified minor opportunities for improvement to reflect good practice by fully cascading safety function and actions on breach of operating rules into operating instructions. No significant observations were made against the arrangements and therefore consider a rating of GREEN, “No formal action” against LC24 to be appropriate.