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 Limited Local Liaison Committee (LLC) and covers activities associated with the regulation of safety at the Urenco UK Limited nuclear licensed site. 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 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’s Nuclear Directorate on 0151 951 3484.
Nuclear Directorate
Health and Safety Executive
Redgrave Court
Merton Road
Bootle
Merseyside
L20 7HS
The site was visited by NII inspectors on:-
The licensee hosted a familiarisation visit to an enrichment facility at the site, by a group of senior French nuclear inspectors, accompanied by an NII Deputy Chief Inspector, on 2nd October.
A site assessment of the licensee’s Approved Dosimetry Service arrangements, in order to reassess the personnel radiation dose recording arrangements, was made on 9th October.
A HSE-HID inspector visited site on 7th November, to provide regulatory advice on the licensee’s Hazardous Substances Consent application, in relation to the proposed Tails Management Facility.
A series of meetings were also held at Bootle, with the licensee’s senior staff, throughout this quarter, to provide regulatory advice to the licensee, regarding improvements required by NII to the licensee’s implementation of licence condition 36 arrangements, in relation to the control of organisational changes.
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.
In June 2008, the licensee’s Managing Director announced the intention to significantly reduce the size of the licensee’s workforce at the site, aiming for a reduction of up to 19%, to be implemented by the end of 2010. The implementation of the licence condition 36 management of organisational change arrangements has therefore received commensurate regulatory assessment, as the licensee’s workforce reduction proposals began to be clarified, towards the end of 2008.
Throughout this quarter, an NII specialist organisational change assessment inspector has conducted sampling assessment of the licensee’s developing organisational change safety documentation, together with assessing some aspects of the implementation of the licensee’s underpinning organisational change arrangements.
The NII assessment has identified the need for the licensee to promptly develop an overarching management of change safety justification, in addition to departmental justifications, together with an up to date organisational “baseline” document, prior to initiating significant staff reductions. This is to ensure that the licensee’s proposed staff reductions will result in the maintenance of adequate organisational resources and the full range of experience and competencies required of a nuclear licensee.
Following site meetings with the Managing Director, the site inspector has written to the licensee, requiring NII visibility of the management of change safety justifications and requiring the licensee to gain the concurrence of NII, prior to the implementation of any further organisational changes, until an appropriate degree of regulatory confidence in the licensee’s implementation of the licence condition 36 organisational change arrangements has been established.
Two NII specialist safety case assessment inspectors visited site in December, in order to assess improvements to the licensee’s safety case production processes and to provide regulatory advice, taking account of the revised published NII 2006 Safety Assessment Principles, (SAPs). Aspects of the licensee’s developing safety case production methodology were assessed, with a positive outcome. A site inspection of the licensee’s implementation of the safety case production process is planned for early 2009.
Urenco UK Limited leads, on behalf of both Capenhurst licensees, regarding the development of emergency arrangements, across the two adjoining Capenhurst nuclear licensed sites. Recommendations provided by NII, following the Level One emergency exercise (on the Sellafield Limited Capenhurst site on 25th November) were discussed with Urenco UK Limited, on 27th November.
Following a minor delay in the licensee reporting to the site inspector a building evacuation from one of the enrichment facilities, (subsequently established to have been due to a false alarm), the site inspector requested the licensee to undertake a review of the licensee’s arrangements for compliance with licence condition 7. The licensee has now completed this review and has provided the site inspector with a timely copy of the revised licence condition 7 arrangements.
No issues arose from the compliance inspections undertaken during this period that required formal regulatory action, beyond the letters sent to the licensee.
In December, Sellafield Limited – Capenhurst Works submitted to NII a request for two Consents, relating to proposals to lease to Urenco UK Limited, two areas of land which are currently owned by NDA and licensed to Sellafield Limited – Capenhurst; NII anticipates issuing these two Consents in early 2009. Following NII issuing those Consents, both Capenhurst licensees then intend making relicensing applications to NII. The objective will be to reconfigure the boundary between the two licensed sites, enabling Urenco UK Limited to incorporate these two leased areas of land, together with six areas of land leased in September, in to the Urenco UK Limited licensed site. Regulatory advice on leasing and relicensing matters, including in relation to the proposed Tails Management Facility, was provided by NII specialist staff, at a site meeting in October.
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.
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. Whilst current storage arrangements remain adequately safe, NII has expressed support to the local planning authority and at meetings involving other government departments, for the timely construction and operation of the Tails Management Facility, (as this should lead to a significant medium term reduction of the hazard associated with the storage of uranium hexafluoride on the licensed site). HSE-HID is separately currently assessing the licensee’s application for the necessary hazardous substances consent, on behalf of the local planning authority. The site inspector had previously provided advice on the licensee’s draft revised related uranium hexafluoride tails policy; a finalised copy of the revised policy is still awaited from the licensee.
Perimeter radiation levels are periodically measured by both the licensee and the Health Protection Agency. Towards the end of this quarter, some unexpectedly enhanced levels of radiation were measured, at the boundary of the Urenco UK Limited licensed site, at levels still well below any regulatory limits, but nevertheless warranting further investigation. This has initiated assessment by an NII specialist health physics assessment inspector.
The site inspector continues to consult with the licensee’s active safety representatives, including participating in a meeting with the safety representatives on 17th December, at which the current regulatory issue, in relation to the licensee’s implementation of organisational change arrangements, was explained by the site inspector.
The site inspector participated in the Local Liaison Committee meeting held on 27th November, verbally reporting on NII site inspection and assessment activities over the preceding five months.
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.