Date(s) of inspection:
Aim of inspection
Hunterston A Site WILWREP is due to enter active commissioning in July 2023. The aim of the inspection is to determine whether the personnel associated with the WILWREP can adequately fulfil their safety duties, in line with the claims made within the safety case for the project.
The required outcome of the inspection is to gain assurance that the operators and maintainers understand and can implement elements of the WILWREP safety case.
Subject(s) of inspection
- LC 10 – Training – Rating: GREEN
- LC 12 – Duly authorised and other suitably qualified and experienced persons – Rating: GREEN
- LC 26 – Control and supervision of operations – Rating: GREEN
Key findings, inspector’s opinions and reasons for judgement made
An inspection of Hunterston A nuclear decommissioning site was undertaken on 30th May 2023 to review the arrangements for LC 26 Control and Supervision of Operations, LC 10 Training and LC 12 Duly Authorised and Other Suitably Qualified and Experienced Persons. I targeted my inspection on the Wet Intermediate Level Waste Recovery and Encapsulation Plant (WILWREP) as this plant was due to start active commissioning in June 2023. However, this has now slipped to October and may slip further. However sufficient progress had been made to allow the inspection to continue.
The results of the inspection were
- A good deal of frustration was evident in the WILWREP planning team regarding the preparations for taking the plant into commissioning. This is due to the stop – start nature of the work which is being interrupted by other current tasks. Discussions were held with senior management about this and it was stated that this situation had arisen due an effort to make progress against a background of resource and funding shortages.
- Planning and organisation of the project work needs to provide adequate time and resource allocation to ensure the requisite infrastructure, procedures and training is in place prior to starting the commissioning of the plant for acid treatment and encapsulation.
- The training arrangements for duly authorised persons (DAP’s) and Suitably Qualified and Experienced People (SQEP’s) has become so complicated that the team is maintaining a separate record of the team’s training on an Excel spreadsheet for simplicity. We were satisfied that the persons scheduled to be allocated to the plant were highly experienced and competent persons. ONR will advise the ONR Magnox Ltd. corporate inspector of this finding.
- Training for new starters to the plant will need to be better defined. Currently the project team and operators are all highly experienced persons and it is not clear that the training system will provide adequate support for those who have no previous experience of these operations. HNA agreed to review the system for needs of new starters.
These findings were accepted by the site management and ONR will follow up preparations for taking the plant into commissioning when the plant is nearer setting to work.
Magnox Ltd. have arrangements to comply with Licence Conditions 10, 12 and 26, and the persons allocated to WILWREP are time-served and highly experienced persons, both generally site-wide and specifically with WILWREP.
The issues discussed regarding the lack of resource and the current stop – start nature of the WILWREP project is not considered to represent a risk to safety. A suitable organisational structure is in place and more effort should become available once the SAWB project completes.
The complexity of the corporate training system is not the fault of the site personnel, who have taken steps to ensure that training of WILWREP management and operators is recorded. This is seen as a corporate issue rather than a site based one, and the ONR Magnox Ltd. corporate inspector will be advised of the findings from this inspection.
Therefore, it is judged that compliance with LC’s 10, 12 and 26 is adequate. (Green)