- Site: Berkeley
- IR number: 22-046
- Date: July 2022
- LC numbers: 7, 17
Purpose of Intervention
This inspection at Magnox Ltd Berkeley was undertaken as part of a programme of planned inspections for 2022/23. The scope of the intervention was aligned to the ONR Decommissioning, Fuel and Waste strategy.
Interventions Carried Out by ONR
This inspection was to confirm adequate implementation of arrangements made under the following Licence Conditions (LCs):
- LC7 Incidents on the site,
- LC17 Management Systems.
The inspection comprised of the examination of procedures, documentation and records and interviews with staff.
The Site Inspector also met with the Trade Union Safety Representatives for the Magnox Ltd Berkeley site and attended the Site Stakeholder Group meeting for the Magnox Ltd Berkeley and Oldbury sites.
Explanation of Judgement if Safety System Not Judged to be Adequate
Key Findings, Inspector’s Opinions and Reasons for Judgements Made
I carried out a themed LC7 and LC17 inspection at the Magnox Ltd Berkeley site. I reviewed the arrangements for these LCs and was able to establish the “golden thread” in the management system for them.
I utilised a near-miss event related to the cross-site transporter to examine the process of event categorisation, reporting of events to external bodies and internal investigation, as a themed example to demonstrate both LC7 and LC17 compliance. I was able to determine that Design Authority arrangements in the Management System for design control and supply chain management align with ONR’s technical assessment guidance on this subject. I was content with the management arrangements in relation to the design and safety justification processes leading up to the event and found the event was appropriately categorised. I assessed the adequacy of the internal site investigation and the further investigation undertaken by the Magnox Ltd corporate centre. During my discussions regarding the internal site investigation report, I asked if an adequate risk assessment was in place for the use of the cross-site transporter on the day of the event. At the time of the inspection Magnox Ltd were unable to provide this evidence and I asked that further information be provided in writing to ONR within two weeks. Both the internal site and further report focussed on LC26 control and supervision arrangements and shortfalls in the communication of safety related information. Advice was sought from the Nuclear Safety Committee (NSC) but there was an inadequate consideration of risk assessments and compliance with the Management of Health and Safety at Work Regulations 1999 (MHSWR99). Magnox Ltd should consider how best to use industrial safety subject matter specialists for similar future investigations and whether the NSC is best placed to give independent advice on industrial safety related events.
Conclusion of Intervention
In my opinion, the Licensee’s arrangements for compliance with LC7 and LC17 are adequate. However, during the inspection, I identified issues relating to the adequacy of the risk assessments and asked Magnox Ltd to write to ONR within two-weeks to confirm compliance with the requirements of Regulation 3(1) and 3(6) of MHSWR99, identifying the actions completed to close any identified compliance shortfalls. Aside from the issue described above, I therefore concluded that this inspection identified no further matters that may impact significantly on nuclear safety.
Post-inspection Regulatory Activities
The Magnox Ltd Berkeley Site Director wrote to ONR on the 10 August 2022 regarding the cross-site transporter near-miss event explaining how the compliance shortfall has been addressed. ONR has assessed the current risk assessments and Plant Operating Instructions as being compliant with MHSWR99 regulations 3 and 10. Following application of the ONR Enforcement Management Model, formal “Regulatory Advice” will be given to Magnox Ltd regarding this event.