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Sellafield Limited
Capenhurst Works

NII site inspector's quarterly report to the local stakeholder group for 1st July 2008 to 30th September 2008

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 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 and are also available on the HSE’s website at http://www.hse.gov.uk/nuclear/llc/index.htm. Site inspectors of HM Nuclear Installations Inspectorate usually attend LSG meetings and will respond to questions raised there by members of the LSG. Any other person wishing to enquire about matters covered by this report may contact the HSE’s Nuclear Directorate on 0151-951-3484/3290.

Nuclear Directorate
Health and Safety Executive
Redgrave Court
Merton Road
Bootle
Merseyside
L20 7HS


Inspections

Inspectors from NII visited the site on the following dates:

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Routine matters

Compliance with Conditions Attached to the Nuclear Site Licence

Each NII site inspector has an inspection programme, informed by planned regulatory interventions.  There are two key regulatory interventions for this site.  The first is to ensure that the structure and resources available to the licensee remain adequate to ensure nuclear site licence compliance, as the hazard on the site reduces.  The second relates to the acceleration of the disposition and ‘deconversion’ of the legacy uranium hexafluoride “Hex Tails”, to the less hazardous oxide form of uranium.

With regard to the licensee’s compliance with licence condition 36, (for the control of organisational change) the licensee has continued to implement arrangements to adequately justifying the ongoing site organisational changes.  This reflects the need to retain adequate “core competence” and “intelligent customer” capabilities, in connection with the developing proposals for the significant reduction in the size of the site workforce, as well as separately enhancing the licensee’s site project management capability, for emerging potential significant new future projects on the site, supporting waste management and hazard reduction objectives. 

It had previously been understood that the ‘down blended’ uranic residues were only to remain on the Capenhurst site for a limited period, pending further processing and recycling at another licensed site.  The licensee is currently proposing to store these materials at Capenhurst for an increased length of time, to permit contractual and processing capacity issues to be addressed, with regard to the subsequent processing at another licensed site.  The revised safety case, to justify the adequacy of the interim storage arrangements, is currently expected to be received from the licensee before the end of 2008.

The licensee continues to prudently actively commission a new facility, being used to empty and wash out some legacy uranium hexafluoride cylinders, with acceptable progress being maintained, as active commissioning issues arise.  This plant is a key facility for reducing the chemo toxic and criticality hazard on the site.  A compliance inspection was made of this facility on 22nd July, with an acceptable outcome.

The licensee sought the Consent of NII to the leasing of six parcels of land to Urenco UK Limited, in accordance with the licensee’s licence condition 3 arrangements.  The areas were inspected on 1st August, (following receipt of the six Consent applications, in late July) and the processing of the six Consent applications was accelerated within NII, fulfilling the request of both Capenhurst licensees, such that the six LC 3 Consents were able to be issued on 9th September, within half of the time normally required by NII to process such legal Consents to lease areas of licensed sites.

Annual Review of Safety & Environmental Performance.

The annual review of safety and environmental performance was held on 8th July, NII being represented by the Head of the inspection unit and the site inspector.  It was agreed that the overall performance of the licensee remained good and there continues to be a positive safety culture, with exemplary participation by the licensee’s safety representatives.  A plant visit was made to a number of decommissioning and radioactive waste management projects, with an acceptable outcome.  

Capenhurst ‘Lifetime Plan’

The site inspector continues to participate in the quarterly regulatory review meetings, involving NII, the Environment Agency, the licensee and the Nuclear Decommissioning Authority, reviewing the licensee’s decommissioning and waste disposals progress against the Lifetime Plan, most recently on 16th September.

NII continues to actively press the licensee to develop the options to bring forward the date for the commencement of processing or disposition 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 remains encouraged that the licensee continues to be actively engaged in reviewing the options to address the “Hex Tails” legacy, with a view to reducing the potential hazard, earlier than currently programmed in the 2008 Lifetime Plan.  NII will continue to press for tangible progress to be made by the licensee in the timely reduction of this medium term site hazard. 

The site inspector continues to press for the timely disposal of solid low level and very low level radioactive wastes from the site by the licensee and for the timely despatch of uranic residues to another licensed site for processing and recycling.  The licensee continues to implement the accelerated disposal of some solid very low level waste, which would otherwise have remained on the site for several decades.  NII welcomed the licensee’s demonstration of this disposal route and continues to encourage the licensee to complete the timely disposal of this particular radioactive waste stream.

Very low level solid waste disposals have continued during the past quarter, further reducing the inventory of radioactive materials on the site.  The licensee proposes to reinstate low level solid waste disposals from the site to the Low Level Waste Repository in the latter half of the current financial year, aiming to complete these low level solid waste disposals by early 2010.  This programme is acceptable to NII. 

There continue to be effective working relationships between the regulators, the licensee and the NDA at the Sellafield Limited Capenhurst site, which serve the interests of each party. 

Conventional Safety Inspection.

A HSE FOD factory inspector made an inspection of conventional industrial safety on 13th August, accompanied by the site inspector.  A number of areas of the site were inspected, accompanied by a safety representative.  Some minor industrial safety matters were raised and advice was provided to the licensee, promptly confirmed in writing, requiring a response, relating to working at height, the use of fork lift trucks and various issues surrounding a cement grouting operation, inspected as part of the solid low level radioactive waste disposal operations.

Local Stakeholder Group

The site inspector participated in a special meeting of the Local Stakeholder Group, held on 1st August, at which representatives of the licensee’s likely new “parent body organisation”, Nuclear Management Partners, sought the priorities of the members of the Local Stakeholder Group.  The NII site inspector emphasised the need for the timely disposition of the legacy “Hex Tails” and the need to demonstrate continuing timely hazard reduction on the site.  Providing that the overall site hazard continued to be reduced and subject to making an adequate safety case, NII would give consideration to some potential alternative uses for parts of the licensed site, utilising the solid low and very low level waste management and decommissioning experience of the licensee.

Meetings with Safety Representatives.

The site inspector continues to consult with the active site safety representatives during site inspections.  The positive initiatives encompassed within the Safety 1st programme, being led by the very active safety representatives, continue to make a significant contribution to the strong site safety culture.

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Non-routine matters

None.

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Regulatory activity

No regulatory enforcement action was necessary in this quarter.

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 Sellafield Limited - Capenhurst Works for complying with those conditions.  The following six Consents were issued in this quarter:

Date

Type

No.

Description

9th September 2008

Consent

504

Licence condition 3(1) Consent to lease a plot of land to Urenco UK Limited.

9th September 2008

Consent

505

Licence condition 3(1) Consent to lease a plot of land to Urenco UK Limited.

9th September 2008

Consent

506

Licence condition 3(1) Consent to lease a plot of land to Urenco UK Limited.

9th September 2008

Consent

507

Licence condition 3(1) Consent to lease a plot of land to Urenco UK Limited.

9th September 2008

Consent

508

Licence condition 3(1) Consent to lease a plot of land to Urenco UK Limited.

9th September 2008

Consent

509

Licence condition 3(1) Consent to lease a plot of land to Urenco UK Limited.