Sellafield Limited Capenhurst Works report - Q2 2009

NII site inspector's quarterly report to the local stakeholder group for 1 April 2009 to 30 June 2009

Inspections
Routine matters
Non routine matters
Regulatory activity
Proposed changes to the status of HSE's Nuclear Directorate
Permissioning

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:

April 2nd, 16th & 17th,
May 6th,
June 23rd, 24th & 30th.

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 three 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. The third relates to the proposed relicensing of the site.

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. The licensee has recently separately enhanced 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 September 2009, a few months later than originally planned to be prepared by the licensee.

The site inspector used the opportunity of ‘refresher' site emergency arrangements training to inspect this aspect of the licensee's implementation of training requirements. Site inspection confirmed that the licensee has now implemented appropriate arrangements to test understanding, following receipt of training.

The site inspector observed the effective co-operation between the two Capenhurst licensees, during a challenging, wide ranging, evening & night shift combined security and emergency arrangements exercise, conducted in April, which was agreed by the team of inspectors to be an adequate demonstration of key aspects of the site security and emergency arrangements.

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.

Both Capenhurst licensees intend making relicensing applications to NII, around August 2009, with a view to the issue of new site licences to both Capenhurst licensees, in early 2010. 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 eight areas of leased land on to the Urenco UK Limited licensed site.

The site inspector participated in a two day audit of aspects of the quality management system, underpinning the licensee's transport arrangements, led by two Department for Transport inspectors, in April 2009. The audit identified that some aspects of the licensee's quality assurance arrangements needed to be updated, to reflect the recent organisational changes within the site licensee, which were readily acknowledged by the licensee and are being addressed. No deficiencies were identified in the implementation of the licensee's arrangements for radioactive materials transport.

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 24th June.

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 licensee has recently assembled a team of over 40 engineering project staff on the site, with welcome funding support from NDA, to accelerate the implementation of these site hazard reduction projects, as well as to enhance the engineering capability of the site.

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. NII is pleased with the continuing progress being delivered regarding solid waste disposals from the site.

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 refreshed 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 most recently in June.

Local Stakeholder Group meeting.

The site inspector participated in the open evening Local Stakeholder Group meeting held in Capenhurst Village Hall on 6th May. The site inspector also reported on recent NII inspection and assessment activities at the Local Stakeholder Group meeting held at Capenhurst on 30th June.

Non-routine matters

None.

Regulatory activity

No regulatory enforcement action was necessary in this quarter.

Proposed changes to the status of HSE's Nuclear Directorate

The Government has put forward proposals to change the status of HSE's Nuclear Directorate (ND) to that of a Statutory Corporation under the auspices of the HSE. This is intended to enable ND, as the independent nuclear regulator of safety and security, to better meet the challenges of a changing nuclear industry over the coming years. The changes are to provide the nuclear regulator with greater flexibility and increase the accountability, transparency and openness of nuclear regulation. The Government are proposing that the statutory changes needed to bring this about will be made by a Legislative Reform Order (LRO).

This builds on the outcome of the Government initiated review of the UK's nuclear regulatory regime, led by Dr Tim Stone. The Summary Recommendations and the Government's response were published at the end of January 2009 (available on HSE's website: http://www.hse.gov.uk/nuclear/stonereview.htm).

A public consultation, run by DWP and DECC, on the LRO was launched on June 30th for a 12 week period, which gives the opportunity for stakeholders to comment on the proposals.

For access to this consultation please see http://decc.gov.uk/en/content/cms/consultations/hse_restruct/hse_restruct.aspx

These new arrangements will not change the substance or standards of regulation or compromise the independence of the nuclear regulatory body, and will not affect the decisions it takes or the international obligations the Government requires it to meet.

Subject to the outcome of the consultation and Parliamentary approval, and if the Parliamentary timetable permits, the aim is to bring the new body into being during 2010.

An internal change programme is currently operating within ND to ensure that the ND is ready to operate as a statutory corporation from spring 2010.

This programme does not in anyway compromise the current regulatory activities of ND.

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Permissioning

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. No Licence Instruments were issued during this quarter.