Health and Safety
Executive / Commission
Nuclear
LLC reports
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 site available to the public. It is for distribution to members of the URENCO (Capenhurst) Ltd Local Liaison Committee and covers activities associated with the regulation of safety at Capenhurst. These reports are distributed quarterly. Site Inspectors of HM Nuclear Installations Inspectorate normally attend LLC meetings and will be happy to respond to questions raised there or subsequently by members of the LLC. Any other person wishing to inquire about matters covered by this report should contact the HSE, Nuclear Directorate Information Centre on 0151 951 4103.
This report will be put onto the HSE Website at www.hse.gov.uk/nuclear/ home under “Local Liaison Committee Reports”.The site was visited by NII inspectors on :-
April 5 th, 19 th, 28 th
May 20 th
June 10 th, 17 th, 29 th & 30 thEach NII Site Inspector has an inspection programme to inspect compliance of operations on the site with the 36 Nuclear Site Licence Conditions (LCs). During this quarter particular attention has been paid to compliance by the licensee to licence conditions :-
No issues were raised from the compliance inspections undertaken during this period which required formal regulatory action to be taken.
A meeting was held to discuss the future demonstration emergency exercise plans for the site. UCL agreed to produce a matrix outlining the elements to be tested in the demonstration emergency exercises over the next 5/10 years. In addition UCL & BNGSL Capenhurst also agreed to produce a programme for the next 5 years of the shift exercises which will be witnessed each year by NII.
The Capenhurst Site Level 2 Demonstration Exercise took place on 19.4.05. The comments from the NII participants at the site, at the NII Incident Response Centre at Bootle HQ and of the NII & Government Technical Adviser (GTA) teams at the Gold Command Centre at Winsford have been incorporated in the report on the exercise. Overall the exercise was considered a success however as usual there were a number of learning points identified.
The latest meeting of the Capenhurst Emergency Planning Consultative Committee (EPCC) was attended. Progress on addressing the actions arising from the Level 2 Emergency exercise “Eagle” will be monitored in future meetings of the Capenhurst EPCC.
The UCL Local Liaison Committee meeting held on 30.6.05 was attended
An inspection was undertaken to investigate how the UCL deal with equipment identified as Safety Mechanisms (SMs) in the safety case documentation. The UCL Plant Managers and staff were able to demonstrate an understanding of the full scope of the SM system identified in the safety case and the details of the required maintenance. Records of the maintenance carried out on the SM equipment were readily obtained and illustrated that the SM system had been tested and maintained as required. Furthermore it was established that the substitution arrangements on failure of the equipment had been thought through. On plant it was evident that a great deal of effort had been employed to ensure that the whole of the SM system had been appropriately labelled.
An inspection was carried out as an initial investigation of the site arrangements for LC19 (Construction or Installation of New Plant). The new chemical labs, which are currently under construction, were used as the focus for the inspection. Overall it was considered that the LC19 arrangements, even though they required to be reviewed, had been adequately complied with for the New Labs project. However during the discussion it was indicated that UCL did not appear to have an approved design change procedure/process. NII & UCL agreed to discuss this topic in further meetings.
NII is currently carrying out a project to investigate the interaction and role of the “Corporate Centre” organisation processes and procedures on the safe operation of nuclear facilities. The NII Project Leader has held discussions with UCL to provide further information for the overall project. The information provided by UCL was considered useful for the NII project to reflect a corporate structure wherein much of the safety management and other management policies, structures and procedures were devolved to the operational site.
E23 Examination, Inspection Maintenance & Testing Arrangements – LC28
Aspects of the implementation of the UCL LC28 arrangements within the E23 facility were inspected. Overall the inspection indicated the E23 Plant Maintenance Schedule (PMS) did reflect the safety case document requirements and E23 were able to demonstrate that the required maintenance had been carried out. Two generic issues were raised from the inspection ie the absence from the plant PMS of the Section C Structures/Systems & Components (SSC) maintenance requirements and the lack of an adequate justification of the maintenance periodicity in the safety case and PMS.
A meeting was held to discuss a potential proposal to delicence an area of the UCL site near the entrance of the site. UCL indicated that this delicensing submission would be forwarded to NII as part of a future relicensing submission covering the various other changes to the UCL site boundary that UCL may be seeking to reflect the future UCL and BNGSL Capenhurst operational plans on the overall site.
A review and discussion of the UCL document outlining the UCL compliance arrangements for LC13 indicated that the document, in general, adequately covered the LC13 requirements. However the inspection raised a number of potential issues relating to the demonstration of the implementation of the arrangements. A further meeting is to be arranged to progress the issues raised from this inspection.
An inspection of the UCL LC12 arrangements as implemented in the A650 operations area was undertaken. It was evident that the workers in this area had been appointed as DAPs & SQEPs according to an established process and had been required to complete an appropriate training programme. Overall it was considered that the fundamental requirements were met but some specific procedural weaknesses were identified. These areas will be followed up in future planned LC12 inspections.
Discussions were attended with UCL and other interested parties regarding possible changes to the routing of the raw water supply to the site.
An EA/NII/UCL meeting was attended to discuss the required work leading to the issue by EA of a new discharge authorisation for the UCL site. A target date of Jan 07 was agreed. UCL restated their intention to plan the next site relicensing submission such that a new site licence could be issued when the new radioactive substances discharge authorisation is granted.
The NII review of the safety documentation associated with the PCSR for the E23G extension to the E23 facility has been completed and an acknowledgement of receipt of the documentation has been issued to UCL.
An inspection of the UCL Approved Dosimetry Service (ADS) for internal measurement and dose assessment was carried out as part of the regular process of reassessment of Approved Dosimetry Services. Some minor points were raised with the ADS for rectification but overall the UCL ADS was considered satisfactory for re-approval.
The NII Report for period Sept- Dec 04 outlined the details of an inspection of the UCL compliance with the Ionising Radiation Regulations 1999 with regard to the arrangements for dealing with sealed sources. No major issues/concerns were identified from the inspection however a number of minor areas for improvement were identified. A follow up inspection has been carried out wherein the actions arising from a previous inspection were reviewed. NII confirmed that UCL have now completed all actions arising from the original inspection.
A NII/UCL Issues/Actions database has been developed to record and monitor actions/issues raised during inspections and meetings etc. The current position on the “open” actions has been discussed and agreed at various times during the report period.
During the period a number of additional miscellaneous topics were progressed including - the requirements for UCL if they become a top tier COMAH site, the need for a further NII/UCL meeting on UCL seismic hazard analysis and the potential land and facility transfers from BNGSL Capenhurst.
Previous reports have outlined the initial NII investigations relating to the incident on site where it was discovered the film inserts for the quarterly film badge issue for the Capenhurst site had been irradiated before issue. A NII Specialist Inspector visited the site to consider the measures taken by UCL to assign estimated doses to the classified and monitored workers on site for the 3 week period in question ie the steps taken to ensure compliance with Reg. 22 of the Ionising Radiations Regulations (IRRs). The initial arrangements made by UCL were examined and considered adequate. The final report of the UCL investigation into this incident has now been reviewed by the NII Specialist Inspector and the placing of the estimated doses on the dose record has also been inspected in detail. The actions undertaken by UCL were considered satisfactory and all actions required have now been completed by UCL.
None
The Inspectorate has powers under the licence to issue Consents, Approvals and Directions. In addition, the Inspectorate uses Licence Instruments to issue Specifications, Acknowledgements and Agreements under either the conditions attached to the Licence, or arrangements made by UCL for complying with those conditions. The Consents/Approvals/Directions and Licence Instruments issued during the quarter were –
DATE |
TYPE |
No |
DESCRIPTION |
|---|---|---|---|
| 27.05.05 | Approval | 502 | Acknowledgement under the arrangements made under Licence Condition 19 of the Pre-Commencement Safety Report for the E23G Plant |
HM Principal Inspector (Nuclear Installations)