Executive summary
Date(s) of inspection
- September 2023
Aim of inspection
Evaluation of the duty holders compliance with the Regulatory Reform (Fire Safety) Order 2005.
Subject(s) of inspection
- Fire (Life Safety) Compliance Inspection – Rating: Amber
- LC28 – Examination, inspection, maintenance and testing – Rating: Green
Key findings, inspector’s opinions and reasons for judgement made
This inspection assessed Magnox Harwell’s arrangements to support Life Fire Safety (LFS) and sampled the implementation of those measures on site. Compliance was assessed using relevant Office for Nuclear Regulation (ONR) inspection guidance, specifically Technical Inspection Guide (TIG) NS-INSP-GD-073 Issue 2 – The Regulation of Life Fire Safety Provision on GB Nuclear Sites. The inspection consisted of examination of the licensee’s arrangements regarding LFS covering the entire site, meetings to assess the implementation and management of LFS at a site level and walkdowns of the H.10, B775 and B220 facilities.
The inspection also sampled evidence of implementation of examination, inspection and maintenance of LFS related equipment which may impact safety as required by License Condition (LC) 28(1).
It was noted that, Magnox (Harwell) had not had a full time Fire Safety Co-Ordinator (FSC) in post for over a year and that the current FSC would shortly be relinquishing the post. Several of the sites Fire Risk Assessments (FRAs) were either only recently updated or were unavailable to ONR as they were being updated. Other FRAs were observed as being significantly out of date as well as fire compartment drawings and some details of buildings and processes. During walkdowns of site facilities large accumulations of combustibles were observed in both the H.10 and B220 buildings. These were not justified in the FRAs available to ONR. ONR requested multiple pieces of evidence to support the inspection. Whilst most of these have been provided by site in a timely manner some key pieces of evidence remain outstanding, this includes the status of all building FRAs across site. Given the above findings a Level 3 issue on Fire Safety Management has been raised to ensure Magnox (Harwell) is meeting its statutory requirements within respect to fire safety and has sufficient resource to continue to do so going forward.
The inspection identified that no maintenance activities were overdue. From the equipment and structures selected the dutyholder was able to provide adequate maintenance and inspection records. Surveys of B220 areas in care and maintenance appear thorough but highlight a number of areas in “poor” condition but not “unacceptable” i.e. degradation mechanisms that are currently affecting key functions or which pose an immediate threat to key functions. Management of facilities in care and maintenance will be a focus of a future intervention.
Conclusion
With respect to the LFS portion of the inspection. Magnox were unable to demonstrate that suitable and sufficient fire risk assessments were available for buildings within the scope of the assessment. Magnox also acknowledged issues with resourcing of fire risk assessors and the fire safety co-ordinator generally. It is my judgement that this is reflected in the number of documents and pieces of information which appeared to be out of date or erroneous. This is also supported by Magnox’s difficulty in supplying supporting evidence following the inspection. In addition, large accumulations of combustibles were observed in separate locations during the audit. A clear process for establishing waste routes, waste quantities and timescales for disposal was not evident. I consider that an ONR inspection rating of Amber “Seek Improvement” is appropriate with regards to the LFS portion of the inspection.
The nominated site inspector has provided the following judgement.
The inspection identified that no safety related maintenance activities were overdue. From the equipment and structures selected the dutyholder was able to provide adequate maintenance and inspection records including follow actions where applicable. I therefore consider that an ONR inspection rating of Green “no formal action” for compliance to LC28 is appropriate