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HM NUCLEAR INSTALLATIONS INSPECTORATE

BNFL SELLAFIELD AND DRIGG AND UKAEA WINDSCALE POWER STATION

Quarterly report for 1 JULY TO 30 SEPTEMBER 2002

CONTENTS


FOREWORD

This report is issued as part of the Health and Safety Executive's commitment to make information about inspection and regulatory activities relating to the above sites available to the public. It is for distribution to members of the Sellafield Local Liaison Committee (LLC) and covers activities associated with the regulation of safety at BNFL Sellafield and Drigg and UKAEA Windscale.

These reports are distributed quarterly and will be available on the Internet. Site Inspectors of HM Nuclear Installations Inspectorate (NII) attend LLC meetings and will be happy to respond to any questions raised there. Any other person wishing to inquire about matters covered by this report should contact HSE, Nuclear Directorate Information Centre on 0151 951 4103.


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1. INSPECTIONS

Inspectors made a total of 64 visits to the Sellafield, Calder Hall, Windscale and Drigg sites during the quarter. This involved a total of 241 days on site (see table 1 for details).

Regulatory Exchange with Japanese Nuclear Safety Regulators

The UK and Japanese governments have an agreement to exchange health and safety information with respect to the regulation of nuclear sites. An inspector from the Japanese Ministry of Economy, Trade and Industry (METI) has been working with our inspectors covering the BNFL Sellafield & Drigg sites during the period of this report. Once he had successfully completed the necessary training, BNFL granted him full access to the site and this greatly assisted in his work. The Japanese inspector observed our inspectors during their routine site activities and was impressed by the open way in which BNFL staff discussed problems with inspectors. He also took a liking to Cumberland sausage and Jennings bitter!


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2. ROUTINE MATTERS

2.1 SITE INSPECTION PROGRAMME

A summary of the work undertaken to meet Site Inspection Programmes (SIP) for the BNFL Sellafield, Drigg and UKAEA sites during the planning year 2002/3 is addressed in this section of the report.

Basic Inspection Programme

The Basic Inspection Programme consists of inspections to verify that BNFL and UKAEA are complying with the conditions attached to their respective licences. Owing to the high priority given to monitoring BNFL's progress in address the Team Inspection recommendations few site wide inspection activities were undertaken during the period (see section 2.2). The more significant issues identified during these inspections are summarised below.

Progress against the emergency arrangements improvement plan has been monitored. The majority of the new Sellafield Site Procedures (SSP) have been approved and are in the process of being issued. These will be progressively implemented over the next 12 months with a full implementation being planned by March 2003. We are content with the progress made to date and the timetable for full implementation.

Inspectors observed exercise "Achilles" used by UKAEA to demonstrate the effectiveness of the Windscale site emergency arrangements. The scenario, a radioactive materials transport incident on a site roadway, was well thought out and particularly challenging and was well simulated. We did not consider that some aspects of the exercise, for example local command and control and contamination control, had been demonstrated to an acceptable standard. However we welcomed UKAEA management's offer to review its arrangements and to carry out a repeat exercise.

2.2 TEAM INSPECTION OF OPERATIONS AT SELLAFIELD

In February 2002 a meeting involving BNFL and NII senior managers was held to review overall progress against the Team Inspection recommendations. It was agreed that the company would aim to achieve close out of the Team Inspection report by October 2002. It was recognized that this date would be challenging as it required a six month acceleration to BNFL's programme. However, we made it clear that the standards against which satisfactory "close out" of the recommendations was to be judged would not be changed. At regular meetings with the company's project team we have emphasized that close out the recommendations will only be made on the agreed basis. This requires the company to submit evidence to show that either (i) the work specified in the agreed task sheet has been met or (ii) sufficient work has been implemented in specified areas to demonstrate the process is capable of being implemented and a programme of work for full implementation on the site has been funded.

During the last period the company submitted claims for completion of the remaining 16 outstanding recommendations. We have agreed to the closure of three recommendations, have requested further information for two more and are still reviewing two others. However, we have found it necessary to reject the company's claims that sufficient work has been done to address 9 of these recommendations as the evidence provided does not meet the agreed criteria for close out. At the time of writing this report we have agreed to the closure of 18 recommendations (nos 1,2,3,6,7,8,9,10,14,15,16,17,18,19,20,23,26 & 28). We anticipate that a closure of several others will be agreed shortly, but judge that it will be some months before we will be in a position to agree to closure of recommendations 4, 11,12, 21 and 22.

In making this assessment we recognize that the company has given a high priority to respond to the Team Inspection report and that significant changes have taken place on the site. Much of the work completed to date has provided the infrastructure to enable improvements to control and supervision to be achieved, but as yet the key arrangements directly affecting control and supervision have not been sufficiently implemented.

BNFL has developed a programme to meet the requirements of licence condition 15 (periodic review and reassessment of safety) to prepare Continued Operations Safety Reports (COSRs) for each plant and service on the site. These COSR documents are submitted to NII in accordance with an agreed programme. In order to provide assurance that the safety case is adequate a selective number of COSRs have been subject to examination and assessment by NII. This work is aimed at providing assurance that the COSRs have been prepared and reviewed in accordance with agreed process and it ensures that an action plan for implementing risk reduction measures has been issued.

Between 1 July and 30 September, two further COSRs were submitted. One COSR for the B212 highly active liquor (HAL) buffer storage facility has been implemented. BNFL took the opportunity to integrate it into with the COSR for the main HAL facility (B215). Preparing the documentation is resource intensive and BNFL are to put proposals for streamlining the preparation of future cases by a Long-Term Periodic Review process.


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3. NON-ROUTINE MATTERS

3.1 GENERAL SITE MATTERS

Relicensing Windscale/Sellafield

Work to enable the issue of new site licences to BNFL and UKAEA to accommodate changes to the site boundaries and the including the transfer of B14.1 to BNFL Sellafield is nearing completion. [NB. The licences were signed on 9 October and came into effect on 16 October 2002].

Fire Safety Action Plan

A review of progress against the Fire Safety improvement plan confirmed that a suite of Sellafield Site Procedures (SSPs) relating to fire safety management have now been issued with a phased implementation programme. BNFL has prioritised the work on plants that have been assessed as having the highest fire risk (category 1 plants) and consider that this work has now been completed. The programme of work is now being extended out to category 2 and 3 plants. We are encouraged to find that the new appointed Fire Safety Advisers are having an effect on the plants and are undertaking routine plant inspections. We have informed BNFL that another site wide fire safety inspection will be undertaken early in 2003 to confirm that the new arrangements are being consistently implemented across the site.

Arrangements for Maintenance - Licence Condition 28

Progress against the Maintenance Improvement Plan has been reviewed. Overall we considered that good progress is being made and it is evident that reorganisation of the Sellafield site to provide a Head of Engineering function has assisted.

Decommissioning Arrangements - Licence Condition 35

BNFL provided the Decommissioning Project Plans (DPP) for the majority of plants that have ceased operations and provided a programme for the preparation of the rest by the end of 2002. We are currently reviewing the information provided and have undertaken to provide feedback during early Nov 2002. However, initial work indicates that some of the DPPs do not meet the company's own arrangements and provide insufficient evidence to show that the plants are going to be decommissioned within a reasonable time scale. Furthermore, the condition of at least one of the plants (B242) is significantly below standard. Enforcement action is being contemplated.

Risk Assessments

BNFL's progress in addressing the requirements of the Risk Assessment Improvement Notice has been monitored. In order to assess the quality of the training provided to personnel required to prepare and authorise risk assessment the "Risk Assessment/Work Safety Planning" training course was attended. Overall we were impressed by the course content and the way in which the information was conveyed to the attendees. We were pleased to find that personnel who were preparing and working with risk assessments were being instructed in the hierarchy of risk controls. Furthermore, the course provided plenty of opportunity for attendees to understand these principles in practice.

Improvement to the Separation Area

An inspection of the improved arrangements for the control of radioactive materials in two plants in the LAEMG area as well as a general inspection of the Separation Area was undertaken. This was done to assess whether the company are likely to be in the position to satisfy the Improvement Notice on this matter. Whilst significant quantities of radioactive waste have been removed from the area we found insufficient evidence to show that the new arrangements had been implemented at the plant. Another inspection has been arranged for mid October 2002. [NB. This subsequently identified that significant progress had been made and that satisfactory discharge of the Improvement Notice was on programme].

Improvement to Containment and Leak Detection Systems - LC34

Progress against the action plan prepared following our earlier LC34 inspection was reviewed. BNFL indicated that a new Sellafield Site Procedure (SSP) had been drafted and that this was to be issued shortly. We highlighted that the company appeared to be waiting for plants to have a completed COSR before addressing the need to ensure compliance with LC34. BNFL maintained that this was not the case and undertook to provide a summary of the work completed by the end of Oct 2002.

Alarm Management Project

BNFL is continuing to take forward "alarm management" as a site wide project. Inspection is currently limited by our resources, which are being directed towards closing out the Team Inspection recommendations. A meeting with the site wide team, followed by a plant inspection of alarm management within High Active Liquid Storage plants, has been undertaken.

Shield Door Improvement Project

Although technical assessment reports have been generated by BNFL, little has been achieved in tangible engineering improvements in the majority of the plants. A letter has been sent requesting the provision of an improvement programme by the end of September 2002. This prompted site management to seek funding for the required engineering improvements on the plant. The Nuclear Safety Committee has asked to be provided with an update on progress on this matter.

Flasks and Container Standards - Licence Condition 17

BNFL proposed a revised action plan, with considerably longer programme timescales to address the recommendations of our inspection of 2000. The scope of the problem seems to be much greater than we had envisaged. A significant proportion of containers do not have defined maintenance regimes. We are in discussion with BNFL regarding programme timescales, in particular with respect to prioritisation of effort on maintenance of the most significant items.

COMAH

We remain concerned with the limited progress made by the company in complying with COMAH. BNFL's Major Accident Prevention Policy (MAPP), a key requirement for a COMAH lower tier site, had not been issued some eight months after notification to us of Sellafield's lower tier status. Revised arrangements for dangerous substance stock control were also not in place. BNFL has since provided us with approved copies of this documentation and an action plan for continuing COMAH compliance.


3.2 INCIDENTS

A number of incidents were investigated by inspectors during the quarter. The details of six events is summarised below and this has been reported in the Sellafield Newsletter. These incidents may be included in a future edition of the HSE Quarterly Statement of Incidents.

False Criticality Alarm

The criticality incident detection (CID) system to B314 alarmed resulting the prompt evacuation of nearly 200 personnel. Whilst B314 does not handle fissile materials it is within the criticality evacuation zone for a number of plants and hence is fitted with a CID alarm system. Investigation confirmed that the alarm was false and that the spurious alarm had been generated as a result of refurbishment work in the area. BNFL has a current programme to implement improvements to the Separation Area CID system and this is due to be operational in mid 2003.

Mis-direction of Analytical Samples in B229

An incident where analytical samples were delivered to the wrong laboratories was investigated. The incident resulted in a sample, which should have been manipulated within a glove box being handled within a fume hood with a consequent potential for contamination of the operator. The investigation confirmed that procedures and labelling performed in the dispatch laboratory had been correctly followed and that wrong delivery had occurred as a result of human error. Although a sample was handled within a fume hood in error, no contamination of the operator occurred. Further reinforcement of the sample labelling process has been proposed to reduce the potential for human error and implementation of a revised procedure will be monitored.

Broken Arm to Operator in B151 Engineering Workshop

HSE's Field Operations Division (FOD) investigated an accident where an operator sustained injuries to his forearm whilst polishing a rotating stainless steel tube. One Prohibition Notice was served regarding use of lathes with a protruding stock bar and another for finishing of rotating workpieces using abrasive cloth. Investigation into the accident is continuing (see section 4).

Failed Fuel Element - Calder Hall

On 7 July following the return to power of Reactor 1, a fuel failure occurred. The reactor tripped on automatic protection and all post trip functions operated correctly. No off site releases were generated. Our investigation confirmed that the staff Hall responded in a conservative and responsible manner both during the event and subsequent investigation and recovery programme. The reactor successfully restarted on 17 July and reached maximum power on 21 July.

Derailment of Flatrol Containing Loaded Fuel Flasks

A joint investigation was carried with specialist HSE Railways inspectors into a derailment of a flatrol containing loaded fuel flasks. There was no damage to either of the flasks. Split points were considered to be the most likely cause of the incident. BNFL has provided re-assurance on the condition of track in the vicinity of the incident, which we observed as having extensive wear, following gauge measurements. Increased staff training on track inspection and maintenance has also been proposed

Inadvertent isolation of electrical supplies

An incident in which a planned electrical isolation led to the unexpected loss of supply to a number of safety significant instruments was investigated. This was caused by the failure of an inverter on demand. The BNFL investigation report is being considered to determine whether further action is necessary.


3.3 MAGNOX REPROCESSING OPERATIONS

Magnox Reprocessing Plant

BNFL shutdown the Magnox reprocessing plant on 6th September for the start of the biennial maintenance period. If the work proceeds to programme, the plant should resume operations at about the end of November. A specification under licence condition 30(3) will be issued requiring BNFL to apply for Consent from the Executive before it can restart reprocessing. A series of meetings have been held to discuss the shutdown and to set down our expectations for granting a Consent to restart operations.

Our inspection activity for the shutdown has included inspection of compliance with operating rules, availability of operating instructions and staff training in these instructions. We have also inspected arrangements for contractor training on hazards associated with the plant. We considered BNFL's arrangements in these areas to be reasonable. However, in some cases, recommendations have been made for improving instructions to more closely reflect operating practices and for improving the audit trail to demonstrate staff training in operating instructions.

We have issued Licence Instruments associated with to two significant modifications to the reprocessing plant that are to be carried out during the shutdown period. These are the replacement of some ventilation filters and the changing of components of the fuel charge machines.

Fuel Handling Plant

Problems with the reliability of equipment associated with the Magnox fuel decanning plant caused the early start of the reprocessing plant shutdown (see above).

BNFL continues to make slow progress with improving pond conditions, in particular with its continued efforts to process poor condition fuel and to re-establish gas seals in the longer stored fuel containers. There continue to be problems associated with the recovery of fuel in poor condition that slows the rate of recovery of pond conditions. We have highlighted our concerns to the company on this matter and are closely monitoring the situation.

Wet Inlet Facility

BNFL has applied for our agreement to allow the facility to enter the active commissioning phase. We are currently assessing the supporting safety submissions and hope to be in a position to issue the agreement in November. The period of active commissioning (to demonstrate the safe operation of the plant in active conditions) is expected to last about one year.

Plutonium Finishing and Storage

During the assessment of storage conditions as part of the B209 COSR preparation BNFL highlighted problems with the safety of both storage and inspection of plutonium oxide currently held in older packaging. We have required BNFL to supply details of programmes for repackaging, inspection arrangements and contingency plans.


3.4 THORP OPERATIONS, INCLUDING HIGH LEVEL WASTE PLANTS

Thorp Operations

Inspection has confirmed that operations have restarted following the planned maintenance outage in July and August 2002. The modification project to Reduce Gadolinium Poisoning in the Thorp Dissolvers (reported last quarter) was implemented on start-up and operations have gone well. Operations/throughput are continuing at the planned rate of about 500 te/yr, which takes into account three planned maintenance outages this year and HAL stocks.

Return of Takahama 4 MOX fuel shipment

This event was surrounded by intense publicity via Greenpeace and all national media in September. The fuel flask was transferred onto the Sellafield site and the returned fuel successfully transferred to the Oxide Fuels Storage pond in a secure location. A number of security measures were put in place.

Prior to receipt of the shipment, our Inspectors had inspected the arrangements for receipt and storage of this fuel, including quality plan, training arrangements etc and were satisfied that appropriate arrangements were in place. During receipt of the consignment, one of the site inspectors observed some of the operations to off-load the fuel bundles from the transport flask and observed that this process was well managed and went smoothly. The fuel will remain in storage until an appropriate strategy for reprocessing has been finalized. BNFL has undertaken to finalize the options and make proposals within 1 year of receipt of the fuel. However, recovery of the fissile material is expected to be a number of years after that.

THORP High Burn-up Fuel processing trial programme

A significant project has been in development for several years and has culminated in BNFL submitting a safety case entitled 'Proposal to process through Thorp the High Burn-up Fuel in the Advanced Fuels Trial Programme'. This proposal covers the reprocessing, in a series of trials, of about 400 te of PWR fuel with burn-ups to 48.8 GWDays/te (compared to the current ceiling of 40 Gwday/te), which is already in stock in the Thorp fuel storage pond. The reprocessing strategy within the proposal is to gradually increase the burn up of the fuel put to the plant. We have assessed the proposal and have concluded that we have no objections to this strategy. A Licence Instrument to enable the project to proceed has been issued.

THORP Head End Plant Dissolver Basket Replacement Project

As reported last quarter, work on the Head End Plant Dissolver Basket Replacement Project has continued. These baskets need replacing because of corrosion of the basket mesh. The corrosion was expected and has been gradual. We have inspected the preparatory work on plant and discussed progress with the BNFL Project sponsor. Most of the equipment is now installed in readiness for the basket changes. The timescale for the Thorp maintenance outage at the end of 2002 and the basket change has been rescheduled to early 2003. This allows completion of the 2002-03 Thorp production programme. The containers holding the 'old' baskets, will be loaded for long-term storage into the B27 pond. The revised programme takes account of improved visibility in the B27 pond water expected in January and February, which will assist container handling. We are satisfied that this project is being well managed and the project management liaison arrangements with NII continue to function well.

High Active Liquid (HAL) Storage Report Update.

In our report reviewing the safety of HAL storage we undertook to provide a biennial review of BNFL's progreess with its response to the reports. NII has undertaken the 1st biennial review and this update summarises information on both compliance with the obligation to reduce HAL stocks in line with the Specification and the progress in addressing the recommendations made in that report and its follow up in 2001.

BNFL has kept within the Specification limit with the operational headroom as intended. A system to monitor volumes of HAL on a consistent basis (known as normalized volumes) has been implemented. BNFL has implemented a trial scheme to measure normalized volumes and once this has been completed we will take a view about modifying the basis of the Specification from an actual volume to a normalized volume.

We are currently looking at improved ways of handling the real matter of safety concern. ie how BNFL manage the risk from these operations. BNFL has already implemented many engineering improvements and continue to do so. However, it has proved very difficult to develop a safety index which addresses all the factors. We continue to press BNFL to develop such an index although the prospect of coming up with single numeric value that represents then safety changes on plant in a simple manner is becoming increasingly remote.

BNFL has put in place a system to address our recommendations that prioritizes them and the other work in the High Level Waste Plants complex. Initially we had some difficulty in seeing that BNFL were making progress with delivering the desired outcomes, despite a commendable process. However the position has improved and regular meetings between NII and the company are being used to monitor progress. Overall, BNFL has made progress with all of the recommendations and there are no short term matters of significant concern. Whilst there have been changes in some parts of this work, overall BNFL has delivered and have been strengthening the team in this work area.

HAL Operations

A meeting with the Corporate Independent Inspector (CII) for High Level Waste Plants was held to review local management's performance at addressing outstanding issues. The site inspector also had meetings and made plant inspections with local safety representatives.

Assessment continues of the safety case to support the continuing receipt of THORP waste liquors into B215. This has been supplemented by further planned submissions, relating to the management of localised elevated temperatures, observed within the Highly Active Liquor storage tanks from time to time. We are actively encouraging the translation of BNFL's R&T development work into further improvements to plant operations. Similarly, we continue to undertake further assessment of the rate of failure of HAST cooling coils.

Medium Active Concentrate Storage

A Licence Instrument was issued to enable the implementation of the integrated HALES plants COSR. The revised modern safety case (COSR) had been assessed and considered to be adequate by NII. BNFL has now successfully implemented this work.

Windscale Vitrification Plant (Lines One and Two)

The Vitrification process continues to operate with a greater throughput; both lines having operated at different times during this quarter. We continue to be encouraged by evidence of BNFL's improved planning (e.g. of major plant maintenance) that has lead to some improvement in the vitrification performance. However, the need to prioritise the accommodation of Magnox reprocessing waste liquors means that Oxide fuel reprocessing will need to be adjusted to match vitrification throughput.

Progress towards the planned implementation of the plant COSR by January 2003 continues to be inspected. Adequate progress continues to be achieved in delivering a range of plant engineering improvements, derived from the new COSR safety case.

BNFL continues to make progress towards installing the important safety upgrades, to bring the hydraulic shield doors up to best modern standards. The proposals to similarly improve the shield door control systems were also discussed in this quarter and these should lead to further plant improvements within the next year.

A further improvement in the rate of transferring the accumulated solid radioactive waste from within the plant to the site store has been delivered in this quarter, following the reinstatement of size reduction equipment on both lines. Waste accumulation within the plant remains a chronic problem, the disposal of which will warrant our continued attention. Improvements to the fire fighting provisions within both lines have also been implemented.

A series of meetings with both BNFL and the Environment Agency resulted in amendments to the proposed new stack discharge authorisation levels for the vitrification plants. These discussions took account of the major nuclear safety requirement to vitrify liquid High Level Waste as well as the need to reduce authorised stack discharge levels.

Windscale Vitrification Plant Line Three.

Active commissioning has continued in this quarter; thirty seven containers have being produced as well as the transfer of vitrified containers to store. The plant has now entered a planned shutdown for the installation of active commissioning modifications. Phased active commissioning operations are continuing to be inspected and assessed. We are supportive of the careful, measured approach being taken to the active commissioning of Line Three.

Vitrified Product Store

BNFL's proposals to rectify the corrosion of the civil structure of the Store have been developed and progress will be monitored throughout 2002. Planned remedial civil works to the external structure commenced in this period.


3.5 MOX OPERATIONS

Sellafield MOX Plant

We inspected BNFL's work associated with the Plutonium commissioning of the plant. This work continued on a phased basis along the production line (which consists of pellet manufacture, fuel rod manufacture, rod assembly into finished fuel elements/bundles and storage of finished fuel elements/bundles). As previously reported, pellet production with plutonium oxide was initiated in SMP at the end of April 2002 to produce MOX fuel pellets. The processing of MOX powder into pellets and the grinding and pellet inspection operations have continued throughout the quarter. Completed inspected pellets are being stored in the purpose designed pellet interim store, awaiting loading into fuel rods (tubes). The pelleting area is currently isolated from the rod production area. In the meantime, Uranium commissioning of the rod production lines has continued. Once the appropriate commissioning checks have been completed and a readiness inspection carried out, MOX commissioning of the rod production lines will commence. NB. MOX reactor fuel is similar to standard PWR and BWR fuel, except that the fuel pellets comprise a mixture of Uranium and Plutonium Oxides, instead of solely Uranium Oxide fuel pellets.

We have carried out several inspections of the pelleting and rod production areas. No significant safety issues were observed, though advice was given on several matters, to which plant management responded positively.

Plutonium/MOX commissioning is intended to last for about another 18 months, after which BNFL will review its safety case in the light of the commissioning results and apply to NII for permission to commence full operation. We continue to monitor progress of the work and advancement of the MOX material along the production line.

MDF

Inspections were carried out of the new arrangements for compliance with Operating Rules, developed as part of the company's response to Team Inspection recommendation 21 and 22. The inspection identified that considerable documentation had been generated by the process ie ORCS, Surveillance Schedules, Operator Response Instructions etc. The new shift handover log arrangements were considered to be good and could be used in other plants. However, improvements to the alarm response instructions and the surveillance undertaken by the plant Duly Authorised Person (DAP) were judged to be necessary as were the quality of the records for detailing the of the status of significant plant.


3.6 SOLID WASTE MANAGEMENT

PCM Strategy

A review of progress against the ILW Specifications since their issue in August 2000 has been made and the current status summarized. A new PCM Strategy is to be presented to the Nuclear Safety Committee shortly. We understand that this will reflect the understandings reached with the regulators and if this is the case it will be formalized through standard regulatory powers.

B100 Series PCM Stores

Further progress has been made since the last report and the B100 stores will have been emptied in advance of the specification deadline. We have asked for the staff involved in the work to be commended for their efforts.

B300 Series PCM Stores

Proposals for emptying the B300 series stores have been presented to the Nuclear Safety Committee. Emptying of the 300 series stores has already commenced and the stores should be substantially empty by 2005.

Drigg PCM Magazines

A Licence Instrument to allow commencement of Active Commissioning of the remaining magazines has been issued following satisfactory preparatory work and safety submissions.The programme for emptying is presently on target and progress is encouraging.


3.7 LIQUID EFFLUENT TREATMENT, WASTE RETRIEVAL AND DECOMMISSIONING

B158 North Group Compound

An inspection of B166 ventilation, containment, and criticality controls identified some inadequacy of records, but the situation was otherwise considered to be satisfactory.

B203

An inspection of the plant safety case and associated clearance certificates identified that the documents had not been reviewed for a number of years. This matter was raised with plant management and an undertaking given that this matter will be dealt with promptly.

B204

Inspection of decommissioning within the plant identified that steady progress with the removal of out-of-cell waste has been made. Optioneering for the HANO stabilisation is being done in a rigorous and systematic manner; the preferred option should be identified later this year. An inspection of shielding systems was carried out. BNFL has recently carried out a thorough review of this topic and is implementing reasonably practicable improvements.

B206

An inspection of the control of operations and operational records was carried out and found to be adequate. Progress with decommissioning has been inspected. Although three of the six cells making up the building have now been decommissioned, the lack of progress with the POCO of cell 3 was disappointing.

B209

Progress with preparations for the decommissioning of solvent cells has been inspected and found to be good. A Licence Instrument to permit the work on the south cells to proceed was issued.

B277

Progress with decommissioning of these facilities has been monitored and found to be satisfactory. The control of these activities on plant was inspected and found to be adequate. We understand that BNFL are ready to commence the final phase of decommissioning work and a submission of an appropriate safety case is expected shortly.

B30

A "no notice", out of hours emergency exercise involving the B30 Shift Team Leader and Shift Co-ordinator was initiated. This identified that there were shortfalls in the availability of trained personnel during silent hours to respond to a serious pond leak. Furthermore, few arrangements were in place to ensure sufficient trained staff could be summoned to staff the Incident Control Centre (ICC) in the short term.

Progress against the discharge of the Improvement Notice requiring the submission of a LC35 Decommissioning Programme was reviewed. This identified that the company are treating the matter serious and have created a 200 strong project team. However, we have yet to be provided with a copy of the project plan and we have gained the impression that emphasis was being given to the discussion of options rather than the identification and implementation of solutions.

Inspection of the new arrangements for compliance with Operating Rules was carried out. These arrangements were said to have been implemented as part of the company's response to Team Inspection recommendation 21 and 22. The inspection identified that considerable documentation had been generated by the process ie ORCS, Surveillance Schedules, Operator Response Instructions etc. However, this appeared to have achieved little improvement at the workplace. Guidance to the relevant plant managers on how improvements could be made was provided. Whilst being critical of the ability of the plant to demonstrate compliance with the relevant Operating Rules the inspector was not concerned with the ability of the plant personnel to respond appropriately to relevant alarms. Discussions with the operators provided confidence that they would act appropriately in the event of significant alarms or faults being raised. Local management were asked to take action to eliminate Operating Rules that were not relevant to current operations and also to rationalize the layout of the clearance certificates.

B38

Progress with the project to make a number of improvements to the cooling capability of the first extension has been closely monitored. Although some delays have occurred due to technical problems, overall the progress is considered to be satisfactory. Progress with the clean-up work to compartment is also being monitored.

An unannounced night shift inspection was carried out; this did not identify any significant issues concerns, although some queries relating to the completion of plant logs raised.

B41

An unannounced night shift inspection was carried out; no issues were identified. Progress with the work to improve the structural stability and containment of the plant was inspected. The BNFL team appears to be committed to carrying out this work as quickly as is reasonably practicable. A plant inspection of SSOW, Emergency Instructions, logs etc and recent changes on plant was carried out. No problems were identified. There have been some false alarms of a silo-fire; these have been followed up with the plant management, and the actions being taken are considered adequate.


3.8 SITE AND PLANT SERVICES, INCLUDING RESEARCH & DEVELOPMENT

Site and Plant Services Annual Review of Safety

The Annual Review of Safety for 2001 had been delayed due to a site re-organisation where departments from various operating units had been transferred to Site and Plant Services. The review indicated that safety improvements had been made during 2001 in, for example, Continued Operation Safety Report implementation and maintenance. Some areas for learning had been identified and an improvement action plan developed.

B229 Technical Laboratories - Analytical Services

The revised system for receipt of analytical samples into B229 seems to have resulted in an overall reduction in anomalies. However, sample mislabelling and out of specification samples from B205 continues to cause difficulties. We have asked B205 to review its sampling arrangements and propose improvements before restart of operations following the present Magnox Reprocessing Shutdown.

Previous inspection had indicated considerable lapse of time between occurrence of an incident and availability of the associated investigation report. Improvements in arrangements for accident investigation and learning from experience (LFE) have been observed. A dedicated post had been created to manage a local event database for tracking progress of investigation reports and actions. There was evidence of liaison with the site LFE team and of promulgation of incidents data within B229.

B235 High and Medium Active Laundry

A review was undertaken of progress against the COSR Improvement programme. We continue to have concerns about BNFL's ability to deliver COSR improvements to agreed timescales. We will continue to monitor progress and consider regulatory action if appropriate.


3.9 CALDER HALL OPERATIONS

Compliance inspections

During these visits the site inspector carried out planned sample inspections of the licensee's compliance with the conditions attached to the Site Licence and other relevant health and safety legislation. Where these inspections revealed that improvements to the site's arrangements were required the site inspector raised them with the Station Manager and is regularly monitoring the Station's response.

Incidents on Site

As part of our planned inspections the site inspector examined the licensee's arrangements for the recording and investigation of events on the station, and undertook independent investigations to the extent that was warranted by the significance of the event. In general he was content with how these matters had been progressed. One event warranted further investigation and this is summarised in section 3.2.

Emergency Exercises

There were no routine witnessed emergency exercises held during the period. Calder Hall's progress towards addressing our requirements for improvement identified during its observation of REDLAC 28 has been further reviewed and is judged as satisfactory. The next Calder Hall demonstration exercise will be held on 16 January 2002. The exercise scenario has now been agreed in principle.

Preparation for Post Operation

The programme of work to define the post operation phase of the station has been discussed. This included the need for a defuelling strategy, the preparation of a post operational safety case and associated operating rules, the introduction of a new maintenance schedule, revised organisation structure and emergency response arrangements.

Annual Performance Review Meeting

This was held on 24 July and attended by the site inspector and Superintending Inspector. Amongst other things this reviewed the good progress being made to implement a programme of improvement to address criticisms made by the site inspector.

Chapelcross Dropped Fuel Incident

Recommendations 9, 10, 11 and 12 of our investigation report of this incident required work to be completed after the resumption of routine defuelling at Calder Hall. We have prevision reported that recommendation 9 as complete. During this quarter we received satisfactory responses to recommendations 10 and 11. Progress on recommendation 12 has continued but, due to the recent Station closure announcement, will now be tailored to reflect the defuelling strategy and period of post operation without any fuel removal. This interim period will be used to modify the fuel route so that more fuel elements can be safely loaded into each fuel transfer flask. These flasks are used to move fuel from Calder Hall to the Fuel Handling Plant where the fuel will be prepared for reprocessing. The programme of work to modify and improve the fuel route will be monitored and regulated as part of the process for ensuring satisfactory preparation for post operation.


3.10 UKAEA WINDSCALE OPERATIONS

Maintenance Arrangements

Four inspectors carried out a maintenance benchmarking inspection. For consistency this was organized along the same lines as that carried out at Dounreay in April 2002. There were several areas of good practice, notably the work of the site Maintenance Improvement Group and the extension of this across other UKAEA sites. The main areas for improvement were on risk assessments and the inconsistency of maintenance instructions. Our inspection findings were presented to local management and are to be confirmed to UKAEA by letter.

Inspection of essential services

An inspection was carried out of the way that UKAEA confirms the adequacy of services provided by BNFL that are essential for the safe operation of Windscale facilities. We concluded that each facility manager needs to establish what essential services are required to support the facility safety case and at what level of reliability, and should ensure that sufficient positive checks are made on the delivery of the services. The site inspector will revisit the matter once UKAEA has considered the matter in more detail.

Pile 1

UKAEA announced that the contract agreements between UKAEA and the Consortium members have been signed. This should enable real progress to be made in engineering a suitable option for decommissioning Pile 1.

WAGR unannounced out-of-hours inspection

An unannounced out-of-hours inspection was undertaken. A range of licence compliance inspections were undertaken, including challenging UKAEA to demonstrate that those on duty were suitably qualified and experienced for the tasks they were undertaking. The impression gained was one of competent staff approaching their tasks with confidence.


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4. REGULATORY ACTIVITY

4.1 PROSECUTION

None

4.2 PROHIBITION NOTICE

FOD/SS/020903/1

This prohibits the use of lathes with protruding stock bars on the BNFL Sellafield site.

FOD/SS/020903/2

This prohibits the finishing of rotating work pieces using abrasive cloth etc on the BNFL Sellafield site.

4.3 IMPROVEMENT NOTICES

None

4.4 SPECIFICATION

None


TABLE 1

QUARTERLY RETURNS FOR

SELLAFIELD, CALDER HALL, DRIGG AND WINDSCALE

DURING THE QUARTER

1 JULY - 30 SEPTEMBER 2002

BNFL SELLAFIELD1 BNFL CALDER HALL 2 BNFL DRIGG UKAEA WINDSCALE
NUMBER OF VISITS 54 3 1 6
INSPECTION DAYS ON SITE 186 13 1 31

ENFORCEMENT ACTIONS 3

2 Nil Nil Nil
Incidents in the quarter likely to be published in HSE's quarterly "Statement of Nuclear Incidents at Nuclear Installations" Nil Nil Nil Nil
CONSENTS, APPROVALS Nil 1 Nil Nil
LICENCE INSTRUMENTS 7 Nil 1 Nil

1 The figures shown for BNFL Sellafield are those for BNFL's chemical plants. They do not include figures for the plants within the Electricity Generation Group (see note 2 below)

2 The figures shown for BNFL Calder Hall are those for the plants on the Sellafield site operated by (or for) the Electricity Generation group, primarily Calder Hall nuclear power plant.

3 An enforcement action may be a Direction issued by HSE under the nuclear site licence, an Improvement Notice, or a Prohibition Notice, or the laying of information in pursuit of a prosecution.


TABLE 2

APPROVALS, CONSENTS, DIRECTIONS AND WITHDRAWALS

ISSUED DURING THE QUARTER

1 JULY - 30 SEPTEMBER 2002

Ref No: DESCRIPTION
BNFL Drigg - Nuclear Site Licence No. 29A
None
BNFL Sellafield - Nuclear Site Licence No. 31F
79 Amendments to an existing Calder Reactor Operating Rule
UKAEA Windscale - Nuclear Site Licence No.46A
None


TABLE 3

LICENCE INSTRUMENTS ISSUED DURING THE QUARTER

1 JULY - 30 SEPTEMBER 2002

REF NO DESCRIPTION
BNFL Drigg - Nuclear Site Licence No. 29A
18 ACKNOWLEDGEMENT OF SAFETY DOCUMENTATION ASSOCIATED WITH EMPTING OF DRIGG MAGAZINES
BNFL Sellafield - Nuclear Site Licence No. 31F
397 SPECIFICATION REQUIRING CONSENT OF THE EXECUTIVE PRIOR TO COMMENCING TRIAL INVOLVING THE USE OF TPP
398 AGREEMENT TO PROCEED WITH CHANGES TO THE ORGANISATION OF SENIOR MANAGEMENT AT SELLAFIELD
399 ACKNOWLEDGEMENT OF RECEIPT OF SAFETY DOCUMENTATION ASSOCIATED WTH THE IMPLEMENTATION OF THE HALES (B215 / B212) COMBINED COSR (& B212 COSC)
400 ACKNOWLEDGEMENT OF RECEIPT OF SAFETY DOCUMENTATION ASSOCIATED WTH THE ACTIVE COMMISSIONING AND WASTE RETRIEVAL FROM THE B209S SOUTH SOLVENT CELLS AT SELLAFIELD
401 ACKNOWLEDGEMENT OF RECEIPT OF SAFETY DOCUMENTATION ASSOCIATED WTH THE MODIFICATION TO AN EXISTING PLANT B205 CHARGE MACHINE BASKET REMOVAL PROJECT
402 ACKNOWLEDGEMENT OF RECEIPT OF SAFETY DOCUMENTATION ASSOCIATED WTH THE MODIFICATION TO AN EXISTING PLANT B205 RED CELL FILTER CHANGE PROJECT
403 ACKNOWLEDGEMENT OF RECEIPT OF SAFETY DOCUMENTATION THORP (B570) ADVANCED FUELS TRIAL PROGRAMME
UKAEA Windscale - Nuclear Site Licence No. 46A
None


Published on the HSE web site 14 February 2003