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 Capenhurst Local Stakeholder Group (LSG) and covers activities associated with the regulation of safety at the Capenhurst Works. These reports are distributed quarterly. Site Inspectors of HM Nuclear Installations Inspectorate normally attend LSG meetings and will be happy to respond to questions raised there or subsequently by members of the LSG. Any other person wishing to inquire about matters covered by this report should contact the HSE, Nuclear Directorate on 0151-951-3484/3290.
This report will be put onto the HSE website at http://www.hse.gov.uk/nuclear/llc/index.htm under ‘Local Liaison Committee Reports’.Inspectors from NII visited the site on the following dates:
A “Fire Safety Audit”, against compliance with the recently revised fire safety legislation, was undertaken on 5, 6 & 7 February, by a HSE fire safety specialist inspector.
Meetings were also held, off the site, with the licensee on 11 January and 2 March, to discuss Safety Performance Indicators, (SPIs). This is a project whereby NII has requested safety performance metrics from all nuclear licensees. BNGSL Capenhurst has proposed a set of safety metrics, which are now being reviewed by NII.
Each NII Site Inspector has an inspection programme, to inspect the licensee’s compliance against the 36 nuclear site licence conditions. NII attention is directed particularly towards inspection of the major “cornerstone” licence conditions.
During this quarter, site inspections have been undertaken across a range of the nuclear site licence conditions.
The site inspector continued to advise the licensee on licence condition 6 regulatory requirements, (relating to documents, records, authorities and certificates) for the planned rationalisation of historic site records. The licensee has now developed a proposal for revised arrangements, being considered by NII.
NII provided advice to the licensee on the regulatory requirements, for the provision, by NII, of licence condition 3 leases, at a meeting on the site.
In respect of licence condition 36, (for the control of organisational change) regulatory advice had earlier been provided, regarding the need for the licensee to retain adequate “core competence” and “intelligent customer” capabilities, relating to the developing proposals for the significant reduction in the site workforce, which the licensee is planning, on completion of the short term decommissioning projects in 2007/08. NII resource constraints have prevented NII from engaging with the licensee on this topic in this quarter. NII aims to agree appropriate regulatory review and hold points, in relation to the licensee’s proposed site organisational changes, in accordance with licence condition 36 arrangements, during the first half of 2007.
An inspection was made of the licence condition 19 and 21 arrangements, (relating to the construction and commissioning of new plant) for the inactive commissioning of the legacy uranium hexafluoride cylinder washing and emptying facility, with an acceptable outcome.
The licensee’s arrangements for controlling the restart of the site incinerator were inspected during a plant inspection, with some improvements being advised by the site inspector.
The Nuclear Decommissioning Authority, (NDA), the owner of the site, requires all of its sites to have an integrated ‘Life Time Plan’, for the decommissioning of the site. The site inspector participated in a regulatory review meeting, involving NII, the Environment Agency, OCNS, the licensee and NDA, reviewing the Lifetime Plan, in order to lobby for improvements to safety.
In particular, NII continues to actively press the licensee to develop the options to bring forward the date for the commencement of processing or disposing of the legacy “Hex Tails” uranic and other materials currently stored on site, taking account of wider developments. The licensee continues to provide the site inspector with visibility of the ongoing work to review acceleration options. NII was encouraged that the licensee was now actively engaged in reviewing the options to address the “Hex Tails” legacy, with a view to reducing the potential hazard from this legacy material, earlier than currently programmed in the Lifetime Plan. Some interim acceleration milestones were incorporated within the 2007/08 Lifetime Plan. NII will continue to press for progress to be made by the licensee towards the timely reduction of this medium term site hazard.
A new ‘parent body organisation’, above the site licensee, is currently being competed by NDA. NII participated in a site visit by the NDA competition team to Capenhurst, to explain the NII regulatory objectives for the site.
There continue to be effective working relationships between the regulators, the licensee and the NDA at Capenhurst, which serve the interests of each party.
Two NII specialist health physics inspectors conducted an inspection at site, (one of a series of such NII inspections, across all licensed sites) in order to assess whether the licensee was taking all appropriate required measures, to minimise the radiation dose uptake to all personnel working with ionising radiations. The licensee’s implementation of radiation dose uptake controls was found to be acceptable. A shortfall in the safety documentation, controlling some decommissioning work, was advised to the licensee during this inspection, with an acceptable response.
A HSE specialist fire safety inspector audited compliance with the requirements of the recently revised fire safety legislation, during an audit of the licensed site, (including West Cheshire College). Whilst the outcome was broadly acceptable, HSE provided advice on improvements required in a number of areas, including the maintenance of safety related equipment, which will be followed up at a further HSE audit, later in 2007.
The site inspector continues to consult with the active site safety representatives during most visits to site. At the request of the NII site inspector, safety representatives accompanied the plant inspections. The site inspector also participated in two Safety Representative Forum meetings during this quarter.
An inspection of solid low level radioactive waste disposals from the site was conducted in March. In contrast to the licensee having disposed of a record quantity of solid low level and very low level radioactive waste during the 2006/07 financial year, NII was concerned to learn that due to available funding, no solid low level radioactive waste was planned to be disposed of, to the Low Level Waste Repository in Cumbria, for the financial year commencing in April 2007. This was a result of the site’s prioritisation of work, to match funding and hazard reduction targets.
The proposed suspension of solid low level radioactive waste disposals represents a significant step change downwards in the waste disposal performance of the site.
NII promptly wrote to the licensee, reminding the licensee of the requirements of the relevant nuclear site licence conditions, relating to minimising the quantity of waste stored on the site and for the disposal of solid wastes from the site. The licensee has a disposal authorisation from the Environment Agency, to dispose of solid low level radioactive waste from the site to the Low level Waste Repository in Cumbria.
In the interests of safety and hazard reduction at the site, NII shall provide proportionate regulatory encouragement to the licensee, to ensure that solid radioactive waste disposals from the site are conducted in a timely manner. As a first stage, NII has written to request the provision of a plan for the restart of solid low level radioactive waste disposals.
No regulatory enforcement action was necessary in this quarter. The licensee’s response to the letter, requesting a plan for the reinstatement of solid low level radioactive waste disposals to the Low level Waste Repository near Drigg, will be carefully considered when it is received.
The Inspectorate has powers under the site licence to issue Consents, Approvals and Directions. In addition, the Inspectorate may use Licence Instruments to issue Specifications, Acknowledgements and Agreements, under either the conditions attached to the Licence, or arrangements made by British Nuclear Group Sellafield Limited, Capenhurst Works, for complying with those conditions.
No Licence Instruments were issued in this period.
BNGSL Capenhurst NII Site Inspector