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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:-

• April      2nd, 16th & 17th
• May       None
• June      12th, 17th, 18th, 25th & 30th.

A meeting was held with the licensee's Managing Director at the HSE-NII Office at Bootle on 14th April, (followed by a meeting at site on 18th June); to further discuss the application of the organisational change licence condition to the ongoing reductions in the licensee's workforce.

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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 five 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, during the ongoing reductions in the number of the licensee's employees.  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, at the proposed Tails Management Facility.  The fourth intervention addresses “Hex Tails” management on the site, as the site stocks are increased, (although limited overall by agreement with NII).  The fifth relates to the proposed request from the licensee for the relicensing of the site, to incorporate eight areas currently leased on the adjoining Sellafield Limited site.

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 and were beginning to be implemented, during the first half of 2009. 

Throughout this quarter, an NII specialist organisational change assessment inspector has conducted sampling assessments 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.  This assessment has been undertaken by NII reviewing the licensee's organisational change safety justifications, together with discussions on site with the Managing Director, managers, supervisors and plant operators, together with consultation discussions at separate meetings with the licensee's safety representatives.  NII has provided extensive regulatory advice to the licensee, defining the expectations of NII, in order to ensure that the licensee appropriately considers all key safety aspects of the proposed organisational changes, which are subject to permissioning by NII.  Progress has been made in the past quarter, NII permissioning a number of the licensee's proposed organisational changes, although considerable further work will need to be undertaken by the licensee, in order to develop adequate safety justifications for further proposed organisational changes.

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. 

Relicensing of 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 around February 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.  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 June.

Licence Condition 11 - Emergency arrangements.

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, held in April.  This exercise was led by Urenco UK Limited and was agreed by the team of inspectors to be an adequate demonstration of key aspects of the site security and emergency arrangements.  This exercise also informed 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 currently planned for later in 2009, informed by the proposed limited NII assessment of the suite of six Tails Management Facility ‘pre commencement' safety cases, NII assessment of which has recently been initiated.

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 had 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.  In June, during a site inspection, two NII specialist health physics inspectors discussed the recently received safety justification from the licensee.  This has enabled NII to subsequently conclude that the licensee has made an adequate safety case, enabling NII to permission the operation of the additional raft storage areas.

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.  Constructive meetings were 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, most recently at Capenhurst on 18th June.  The licensee's parent body organisation board has very recently financially sanctioned the construction of the Tails Management Facility.  Regulatory advice has been provided to the licensee, to ensure that adequate control and supervision of all safety aspects of the TMF project, including the forthcoming construction work, is adequately addressed by the licensee's organisation.

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 still continuing to be reviewed by an NII specialist health physics assessment inspector.  Further discussions are proposed between NII and both Capenhurst licensees.

Safety Representatives.

The site inspector continues to consult with the licensee's active safety representatives, most recently participating in a meeting with the safety representatives, on 17th June, 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.

Local Liaison Committee.

The site inspector participated in the Local Liaison Committee meeting, held at Capenhurst on 30th June, providing an update on recent NII inspection and assessment activities.

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Non-routine matters

None.

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Regulatory activity

No regulatory enforcement action was necessary in this quarter.

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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 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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