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 UK Ltd Local Liaison Committee (LLC) and covers activities associated with the regulation of safety at the Urenco UK Ltd nuclear licensed site. These reports are distributed quarterly and are available also from the Internet at http://www.hse.gov.uk/nuclear/index.htm. Site inspectors of HM Nuclear Installations Inspectorate usually attend LLC meetings and will respond to questions raised there by members of the LLC. 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
The site was visited by NII inspectors on:-
Each NII site inspector has an inspection programme, informed by planned regulatory interventions. There are three key regulatory interventions for this site.
The first is to permission the licensee’s commercial activities, whilst ensuring continued site licence compliance. The second is to ensure that the structure and resources available to the licensee remain adequate to ensure nuclear site licence compliance. The third relates to the permissioning of the arrangements for the safe storage and timely ‘deconversion’ of the uranium hexafluoride “Hex Tails” into the more stable, less hazardous oxide form of uranium.
Regulatory advice was provided to both Capenhurst licensees, at a meeting held on the Urenco site on 12th August, to consider the licensee’s forthcoming request for the future relicensing of the site and related leasing matters.
No issues arose from the compliance inspections undertaken during this period that required formal regulatory action.
A team of three inspectors, (one from HSE-HID and two from NII), led by the site inspector, observed a ‘silent hours’ shift emergency exercise, (exercise “Elm”) on the evening of 5th August 2008. The inspectors observed the site emergency control centre, the forward control point and at the scene of the simulated event, within one of the enrichment facilities. Overall, NII concluded that the exercise was an adequate demonstration of relevant aspects of the licensee’s ‘on site’ licence condition 11 emergency arrangements. The licensee is addressing a number of minor shortfalls observed during this emergency exercise. The licensee was observed to have encouragingly implemented adequate measures to address the shortfalls in record keeping, observed and commented upon by NII during recent Capenhurst emergency exercises. A site meeting was held on 18th August, to explore the potential to combine the NII and ND-OCNS observed exercises in 2008, with a positive outcome.
A HSE FOD factory inspector made an inspection of conventional industrial safety on 13th August, accompanied by the NII site inspector. An inspection was made of the installation of new enrichment plant facilities, accompanied by a safety representative, with a broadly satisfactory outcome.
Discussions have continued with the licensee regarding the commissioning of additional raft storage areas for uranium hexafluoride cylinders on the site. NII has accepted the licensee’s proposal to commission the storage raft with a limited number of uranium hexafluoride cylinders, in stages, after each of which the radiological impact would be reassessed by the licensee and reported to NII, before further uranium hexafluoride cylinders were placed on to the new storage raft.
Two inspections were conducted in January and February 2008, by the site inspector, an NII specialist inspector and the Environment Agency site inspector. The inspections involved the reorganisation of the Health, Safety & Environment Department and the Management Systems and Business Improvement Department into a Compliance Department, under a new departmental head. The licensee had provided the associated “Management of Change” safety documentation, in accordance with the site licence condition 36 arrangements, for assessment by NII, prior to implementation of this organisational change. Following subsequent regulatory discussions, the Managing Director implemented additional organisational change arrangements, to improve the new organisation’s ability to demonstrate an appropriate level of safety management. It was agreed that the effects of the organisational change would be formally reviewed by both the licensee and NII over the next twelve months. The Managing Director’s review, six month after this change, is currently being assessed by NII. In June 2008, the licensee announced the intention to significantly reduce the size of the licensee’s workforce at the site. The implementation of the licence condition 36 management of organisational change arrangements will therefore continue to receive regulatory attention, as the licensee’s workforce reduction proposals are clarified in the latter quarter of 2008.
Sellafield Limited – Capenhurst Works submitted to NII, (on 22nd July 2008) a request for a suite of six Consents, relating to proposals to lease to Urenco UK Limited, six small areas of land which are currently owned by NDA and licensed to Sellafield Limited - Capenhurst. The proposals cover areas of the site associated mainly with electrical distribution and fire fighting water supply facilities. These six Consents were issued to Sellafield Limited Capenhurst on 9th September 2008, fulfilling the licensee’s request to accelerate the issue of the necessary legal Consents by NII, (NII achieving this within half of the time normally required to assess and process such licence condition 3 Consents within NII). The plan is to eventually reconfigure the boundary between the two licensed sites, for which a relicensing request is currently anticipated to be made to NII in early 2009.
A plant is proposed to be constructed on the licensed site to ‘deconvert’ the uranium hexafluoride “Hex Tails” to the more stable, less hazardous oxide form of uranium, for longer term storage. Further discussions have been held between the licensee and the regulators, including a site meeting involving HSE-HID and the site inspector, on 18th July, regarding the development of the associated safety case and other regulatory permissioning requirements for this new facility. Whilst current storage arrangements remain adequately safe, NII expressed support for the timely construction and operation of the Tails Management Facility, (as this should lead to the medium term reduction of the hazard associated with the storage of uranium hexafluoride on the licensed site) in a letter sent to the local planning authority, who have subsequently given outline planning permission. HSE-HID is currently assessing the licensee’s application for the necessary hazardous substances consent. The site inspector provided advice on the licensee’s draft revised related uranium hexafluoride tails policy, a finalised copy of the revised policy is awaited from the licensee.
The site inspector continues to consult with the licensee’s active safety representatives.
None.
No regulatory enforcement action was necessary in this quarter.
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 Urenco UK Limited for complying with those conditions. No Licence Instruments were issued during this quarter.