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 and are available also on the Internet at http://www.hse.gov.uk/nuclear/llc/2008/index.htm. 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’s Nuclear Directorate on telephone number 0151 951 4103.
Nuclear Directorate
Health and Safety Executive
Redgrave Court
Merton Road
Bootle
Merseyside
L20 7HS
Inspectors from NII visited the site on the following dates:
Licence condition 36 (control of organisational change) inspections were also conducted at the Sellafield Works site, involving NII inspectors and the directors of Nuclear Management Partners Limited, NMPL. NMPL is the corporate body, which was appointed by the Nuclear Decommissioning Authority, as the “parent body organisation” for the nuclear site licence holder, (Sellafield Limited) on 24th November 2008
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 until 2011, pending processing and recycling 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 in the first quarter of 2009.
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. This plant is a key facility for reducing the chemo toxic and criticality hazard on the site. The site inspector discussed the licensee’s investigation of a minor event, relating to the unexpected routing of some of the uranic materials, during active commissioning, concluding that the licensee’s investigation was appropriate.
In December, the licensee sought the consent of NII to the leasing of a further two parcels of land to Urenco UK Limited, in accordance with the licensee’s licence condition 3 arrangements. NII is currently assessing these applications and anticipates issuing the relevant ‘Consent’ licence instruments in early 2009.
A team of four NII inspectors and one ND-OCNS inspector observed the Level One emergency exercise, which was deemed by NII to be an adequate demonstration of the emergency arrangements. A simulated criticality event, with three casualties, provided an appropriate test of the ‘on site’ emergency arrangements. Key objectives for the exercise were achieved, with a number of minor learning points being readily recognised by the licensee at the ‘wash up’ meeting. Effective co-operation between the two Capenhurst licensee companies was appropriately demonstrated.
The site inspector continues to participate in the quarterly regulatory review meetings, involving NII, the Environment Agency, the licensee and the Nuclear Decommissioning Authority, (NDA), reviewing the licensee’s decommissioning and waste disposals progress against the Lifetime Plan, most recently on 17th December.
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 within 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. Site meetings were held with the Head of Site and the NDA Commercial Director on this topic in October and with the incoming (NMPL) Infrastructure Director in November.
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 has creditably continued to accelerated disposal of some solid very low level wastes, which would otherwise have remained on the site for several decades. NII welcomed the licensee’s implementation of this disposal route and continues to encourage the licensee to complete the timely disposal of this particular radioactive waste stream in 2009.
Very low level solid waste disposals have continued during the past quarter, further reducing the inventory of radioactive materials on the site. The licensee has also encouragingly reinstated low level solid waste disposals from the site to the Low Level Waste Repository in this quarter, 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.
Following the HSE FOD inspection of conventional industrial safety on 13th August, a satisfactory response to the issues raised during that inspection was received from the licensee, confirming the timely implementation of a number of safety improvements on the site.
The site inspector participated in the meeting of the Local Stakeholder Group, held on 27th November. The NII site inspector reported on site inspection findings over the preceding six months and addressed minor queries at this meeting. The site inspector also commented that 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.
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.
None.
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 Consent and Agreement were issued in this quarter:
| Date | Type | No. | Description |
|---|---|---|---|
| 12th November 2008 | Consent | 510 | Licence condition 3 (1) Consent to lease Nuclear Decommissioning Authority owned land to Sellafield Limited Capenhurst. |
| 18th November 2008 | Agreement | 511 | Licence condition 36 (1) Agreement to commence an organisational change transition, of the Sellafield Limited “parent body organisation”, from BNFL plc to Nuclear Management Partners Limited, as part of the NDA competition programme. |