- Site: Harwell
- IR number: 20-033
- Date: September 2020
- LC numbers: 21, 10, 12, 28
Executive summary
Purpose of Intervention
This themed inspection on the Harwell licensed nuclear site was undertaken as part of a programme of planned interventions as outlined in the Magnox Ltd southern sites’ inspection plan for 2020/21.
Interventions Carried Out by ONR
During this “Restart” Themed Inspection related to Magnox Ltd and contractor operations at the Liquid Effluent Treatment Plant (LETP) decommissioning project. Evidence was sought of adequate implementation of the following Licence Conditions (LC):
- LC10 Training
- LC12 Duly authorised and other suitably qualified and experienced persons
- LC21 Commissioning
- LC28 Examination, Inspection, Maintenance and Testing
The inspection comprised plant inspection, examination of procedures and records and interviews with staff
Whilst on site the Magnox Ltd Harwell/Winfrith Site Director organised an introductory meeting between the incoming ONR Nominated Site Safety Inspector and his lead team. The incoming inspector also visited the B462 complex.
Explanation of Judgement if Safety System Not Judged to be Adequate
Not Applicable.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
I carried out a “Restart” LC 10, 12, 21 and 28 themed inspection at the Liquid Effluent Treatment Plant (LETP) decommissioning project following a period of pause of operations due to the COVID-19 pandemic. During this inspection, I reviewed the licensee’s arrangements to “Restart” operations in compliance with COVID-19 government guidance and Magnox Ltd arrangements for compliance with these to ensure due regard was given to existing hazards and risks associated with operations on the Nuclear Licensed Site.
Magnox Ltd Harwell/Winfrith followed a standardised corporate approach to safely restart operations by means of a Quality Plan. Adequate arrangements were in place to safely shut down operations Harwell/Winfrith. During the period of “pause” arrangements were developed and shared with ONR to restart operations. In order to inspect this new process it was my opinion the arrangements most closely matched those for LC21.
I reviewed the existing arrangements for LC10 and LC12. Compliance with these requirements formed part of the “Restart” Quality Plan, which had been appropriately signed off by the LETP Authority to Operate Holder. I established the “golden thread” in the Management System for LC12 from the top level compliance statement to the completion of the local form.
I examined the training records of SQEP personnel on site and interviewed a SQEP member of staff responsible for maintaining the LETP radiation portal monitor for outgoing waste consignments who was able to show me the LC28 - Examination, Inspection, Maintenance and Testing record for the portal, appropriately signed and dated. I discussed the process for checking the current competence of contractors on the LETP site with the Magnox Ltd Decommissioning Project Manager, a training matrix was used by Magnox Ltd to ensure all contractors on site were sufficiently SQEP, however as previously found in inspections at Winfrith, no list of recognised industrial standards/accreditations for trades, is provided in the Management System and reliance is placed on experienced manager to know the appropriate standards. From the documentation sampled and the staff interviewed it is my opinion compliance with Licence Conditions 10, 12 and 28 is being maintained and was complied with for the restart of operations at LETP.
During my plant walk-down of the LETP facility I inspected the changes made on site to ensure compliance with Magnox Ltd arrangements for COVID-19 secure operations, which in my opinion have been adequately implemented.
Conclusion of Intervention
Based on the evidence gathered during this inspection, I consider that the Licensee has made and implemented adequate arrangements for compliance with LC10, 12, 21 and 28 during the “Restart” of operations of Magnox Ltd Harwell and given due consideration to compliance with Government guidance for COVID-19 secure working.