Sellafield Limited Capenhurst Works report - Q1 2009

NII site inspector's quarterly report to the local stakeholder group for 1 January - 31 March 2009

Inspections
Routine matters
Non routine matters
Regulatory activity

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. 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.

Inspections

Inspectors from NII visited the site on the following dates:

January 9th & 21st,
February 6th,
March 10th, 16th, 19th, 24th, 25th & 27th.

A letter was sent to the licensee requesting a review of the inspection and maintenance arrangements for assessing the integrity of buried LPG pipe work.

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 justify the ongoing site organisational changes. This reflected the need to retain adequate “core competence” and “intelligent customer” capabilities, in connection with the recent implementation of a phased reduction in the size of the site workforce, as some recent decommissioning and waste disposal projects were completed. The licensee is separately enhancing the licensee's site project management capability, for emerging potential significant new future projects on the site, supporting further waste management and hazard reduction projects.

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 around 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 by June 2009.

The site inspector used the opportunity of refresher site emergency arrangements training to inspect this aspect of the licensee's implementation of training requirements. Advice was provided to the licensee to incorporate some written testing of the understanding of the training delivered by the licensee. The licensee has agreed to implement this change.

The licensee continues to prudently actively commission a new facility, being used to empty and wash out some legacy uranium hexafluoride cylinders, with acceptable overall progress being maintained. This plant is a key facility for reducing the chemo toxic and criticality hazard on the site. The site inspector conducted a plant inspection of the preparations for re-commissioning this plant, in March. The licensee was encouragingly observed to have implemented a number of tangible engineering improvements to the plant, building on the earlier active commissioning experience.

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 assessed these applications and inspected these two parcels of land in January, (subsequently ensuring that the low level of fixed radioactive surface contamination of one of he parcels of land was effectively communicated to Urenco UK Limited), before issuing the two relevant ‘Consent' licence instruments in February. Following NII issuing those Consents, both Capenhurst licensees intend making relicensing applications to NII, around mid 2009, with a view to the issue of new site licences to both Capenhurst licensees, around the end of 2009. The purpose of the two new site licences 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 similarly leased in September 2008, in to the Urenco UK Limited licensed site.

Early on the morning of 28th January, a containerised low level solid radioactive waste road shipment, en route from the site to the Low Level Waste Repository near Drigg, was involved in a road traffic event, about a mile after leaving the site. The one third height ISO container, containing solid low level radioactive waste, was being transported on an extendable sliding skeletal road trailer. The rear six wheel bogie had parted from the trailer main chassis, causing the rear of the main chassis to come into contact with the road surface. The waste container remained locked on to the trailer main chassis. There was no leakage of radioactive waste material, confirmed by prompt contamination monitoring at the scene. The waste container was promptly retrieved to the site, after lifting the waste container on to another trailer, using a mobile crane. The extendable skeletal road trailer vehicle was removed and inspected by VOSA with no obvious pre-existing engineering defects being found. Some shortfalls in the control of the securing of the two parts of the extendable skeletal trailer were subsequently promptly identified. Various aspects of this event were also of interest to the Cheshire Constabulary and the Department for Transport, liaising with the site inspector. The licensee's relevant emergency arrangements, in response to the event, were promptly and effectively implemented. The site inspector has assessed shortfalls in aspects of the training and instructions provided to transport drivers. The licensee's prompt investigation into this event, together with a separate wider review of transportation issues, (across the licensee at Sellafield and at Capenhurst, undertaken by the Head of the Capenhurst Site), has been assessed by the site inspector as being appropriately rigorous and wide ranging, also being promptly communicated to NII and others. The licensee has agreed to the site inspector's request for the licensee to promulgate the key lessons learned from this event, across the nuclear industry, through the Safety Director's Forum. The site inspector is planning to participate in an audit of the licensee's transport arrangements, led by Department for Transport inspectors, planned for April 2009.

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, (NDA), reviewing the licensee's decommissioning and waste disposals progress against the Lifetime Plan, most recently on 16th March.

NII continues to actively press the licensee (and where appropriate, NDA, who supply funding and also inform aspects of the licensee's strategy) 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 and NDA have continued to provide the site inspector with clear visibility of the substantial ongoing work to review the 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, significantly earlier than currently programmed within the 2009 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 has creditably continued to implement the 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, before the end of 2009.

Low and very low level solid waste disposals have continued during the past quarter, further reducing the inventory of radioactive materials on the site. It is understood that the low level solid waste disposals from the site to the Low Level Waste Repository are planned to be completed by early 2010. This programme is acceptable to NII.

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

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 effectively led by the very active team of safety representatives, continue to make a significant contribution to the strong site safety culture. The site inspector met with the safety representatives in March and was later in the month then also joined by the Superintending Inspector, (Head of ND Unit 2B) when participating in the event and exhibition, held on the site, to launch the 2009/10 Safety 1st programme, in late March. NII mounted a stand on the ‘work of NII' and were able to speak to safety representatives from the licensee and other sites, together with the licensee's workforce and contractors, at this very well attended “Safety 1st” launch event.

Non-routine matters

None.

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 two Consents were issued in this quarter:

Date	Type	No.	Description
25th February 2009	Consent	512	Licence condition 3(1) Consent to lease a plot of land to Urenco UK Limited.
25th February 2009	Consent	513	Licence condition 3(1) Consent to lease a plot of land to Urenco UK Limited.