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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 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. 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.

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Inspections

The site was visited by NII inspectors on:-

• January - None
• February 4th, 6th, 10th, 12th &18th
• March 16th

The licensee's Managing Director hosted a well received familiarisation visit to an enrichment facility at the site, by a group of senior American nuclear regulators, accompanied by the site inspector, on 4th February 2009.

A meeting was held with the licensee at Bootle, on 15th January, in order to continue 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.

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.

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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 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.

Licence Condition 36 - The control of organisational change

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 related licence condition 36 management of organisational change arrangements has therefore continued to receive commensurate regulatory assessment, as the licensee's workforce reduction proposals were further clarified, during the first quarter of 2009.

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. On 12th February, a meeting was held at site, to discuss proposed staffing reductions within the Operations Department. This was followed, later that day, by site inspections of two of the enrichment facilities and two NII inspectors observed the evening shift handovers of Operations Department staff, (control room operators, team leaders and then shift managers) to further inform the ongoing NII assessment.

The NII assessment had identified the need for the licensee to develop a timely overarching management of change safety justification, in addition to the separate lower tier departmental justifications, together with an up to date organisational “baseline” document, prior to implementing significant staff reductions. This was to ensure that the implementation of the licensee's proposed staff reductions would still maintain adequate organisational resources and the full range of experience and competencies required of a nuclear licensee. The licensee provided early draft versions, followed by a finalised version on 30th March, of this overarching management of change safety justification, which will receive timely NII assessment.

Following site meetings with the Managing Director in late 2008, the site inspector wrote 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. The licensee has complied with this request, providing NII with visibility of the lower safety category management of change safety justifications. NII has responded to the licensee, assessing the first of these lesser safety significant organisational changes, within the agreed period of one month for the limited NII assessment.

Licence Condition 3 - Restriction on dealing with the site

In December 2008, 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 were currently owned by NDA and licensed to Sellafield Limited - Capenhurst. NII issued these two Consents in February 2009. 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. 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 March.

Licence Condition 11 - Emergency Arrangements

The site inspector participated in the Emergency Planning Coordination Committee meeting, involving both Capenhurst licensees. (Urenco UK Limited leading on emergency arrangements), the local authorities and the regulators. Adequate progress was reported towards addressing the remaining actions from the Level Two ‘off site' emergency exercise, held in 2008. The Off Site Emergency Plan for Capenhurst was revised and reissued in this quarter. A separate site meeting was also held to discuss the scope of a forthcoming ‘silent hours' exercise, to be observed by NII. This exercise will also inform the ongoing organisational change assessment by NII.

Licence Condition 14 - Safety Documentation

Two NII specialist safety case assessment inspectors visited the site in December 2008, 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 mid 2009, informed by the proposed NII assessment of a Tails Management Facility ‘pre commencement' safety case.

The developing safety case for additional raft storage projects

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.

Proposed Tails Management Facility, (TMF)

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 had expressed support to the local planning authority and to 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. A constructive meeting was held with both the licensee, together with Urenco ChemPlants Limited, (who are proposing to construct and operate the TMF facility on the Urenco UK Limited licensed site) and the relevant regulatory staff, to provide regulatory advice, at Capenhurst on 18th February. The first facility safety case has been sent to NII and some limited NII assessment of this safety case has recently been initiated.

Licensee's Hex Tails Policy

The site inspector had previously provided verbal advice on the licensee's draft revised related uranium hexafluoride tails, (Hex Tails) policy; written confirmation of this advice was provided to the licensee in March. The licensee is in the process of confirming the long standing agreement with NII to limit the Hex Tails inventory on the licensed site, to within an appropriate numerical limit, within the revised policy.

Site perimeter radiation levels

Perimeter radiation levels are periodically measured by both the licensee and independently by the Health Protection Agency. In late 2008 and subsequently confirmed in early 2009, 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 ongoing assessment by the licensee, which is continuing to be reviewed by an NII specialist health physics assessment inspector.

Safety Representatives

The site inspector continues to consult with the licensee's active safety representatives, most recently participating in two meeting with the safety representatives, on 6th and 12th February, at which the key current regulatory issue, in relation to NII assessment of the licensee's implementation of organisational change arrangements, was explained to the safety representatives by the site inspector and an NII specialist organisational change assessment inspector.

No issues arose from the compliance inspections undertaken during this period that required formal regulatory action, beyond the letters sent to the licensee.

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Non-routine matters

None.

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Regulatory activity

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.

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