LLW Repository Limited, Drigg - quarterly report for Quarterly report for 1 January to 31 March 2009

West Cumbria sites stakeholder group

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 West Cumbria Sites Stakeholder Group (WCSSG) and covers activities associated with the regulation of safety at the LLW Repository nuclear licensed site. These reports are distributed quarterly and are available on the HSE's web site located at: http://www.hse.gov.uk/nuclear/llc/index.htm. Site Inspectors of HM Nuclear Installations Inspectorate (NII) normally attend WCSSG meetings and will be happy to respond to questions raised there or subsequently by members of the WCSSG.

Inspections

The Nuclear Installations Inspectorate (NII) Site Inspector visited the LLW Repository main offices during the quarter as follows:

11 March 2009

Routine matters

Inspections at site

Inspections are undertaken at site as part of the process for monitoring compliance with:

The conditions attached by HSE/NII to the nuclear site licence;
The Health and Safety at Work etc Act (HSWA) 1974; and
Regulations made under the HSWA, for example, the Ionising Radiations Regulations 1999 and the Management of Health and Safety at Work Regulations 1999.

This entails monitoring licensees' actions on the site in relation to incidents, operations, maintenance, projects, modifications, safety case changes, and any other matters that may affect safety. The licensees/operators are required to make and implement adequate arrangements under the conditions attached to the licence to ensure legal compliance. Inspectors judge both the adequacy of such arrangements and their implementation.

In the period, no specific routine inspection of LLW Repository took place on site; however, the Site Inspector kept in touch with events on the site and spoke to senior staff about some minor issues involving the transport of radioactive material between the Drigg site and Sellafield sites

Non-routine matters

Licensees are required to have arrangements to respond to non-routine matters and events. NII inspectors judge the adequacy of the licensee's response, including actions taken to implement any necessary improvements.

Some administrative errors occurred with transfers of radioactive materials between LLW Repository and Sellafield sites, one of which led to a lorry that was carrying material from Capenhurst (Sellafield Limited) to LLW Repository being involved in an accident. No radioactivity escaped. A joint LLW Repository and Sellafield investigation team has looked into the transport problems and has identified a need for some improvements. Another event involved a worker who contaminated one hand and a work glove, but did not find out until the following day. The contamination was removed and thorough checks were carried out at Sellafield site and LLW Repository and on the worker's personal property to find the source and to ensure that it had not spread anywhere else. This and the other events were of very minor significance, but they have led both the licensee to improve their arrangements to minimize the possibility of repetition.

Changes to HSE's Nuclear Directorate

In early 2008, the Government initiated a review of the UK's nuclear safety regulatory regime, led by Dr Tim Stone. The recommendations and the UK's Government response were published at the end of January 2009. One of the major recommendations is the decision by Government to establish the Health and Safety Executive's (HSE) Nuclear Directorate (ND) as a Statutory Corporation under the auspices of the HSE.

The creation of this new, autonomous body, (which will continue to incorporate the Office for Civil Nuclear Security and the UK Safeguards Office) will facilitate a more sustainable approach to regulating nuclear safety and security within a rapidly changing global nuclear environment and recruitment of a high calibre of staff within a hardening market place for highly specialised skills.
The restructuring will not change the substance or standards of regulation nor 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.
Enabling work continues for the initial scoping and planning of the work-streams and programmes necessary for the Statutory Corporation to come into being from April 2010. This project has required the temporary enhancement of ND's senior management capability in order to deliver existing regulatory work and to create the Statutory Corporation.

Safety Performance Indicators

During the period, NII conducted a review of all its sites' progress with meeting a long-term initiative that encourages licensees to establish and monitor appropriate indicators for judging their safety performance. Although LLWR has existed as a site for many years, as a low-hazard site that was also undergoing major reorganization for the Nuclear Decommissioning Authority competition programme, NII has only recently asked them to participate in the scheme. The site staff were already aware of the proposal and informed the Site Inspector that they would consider how best to take things forward.

Regulatory activity

Under Health and Safety legislation NII Site Inspectors, and other HSE Inspectors, may issue formal documents to ensure compliance with regulatory requirements. Under nuclear site licence conditions HSE/NII issues regulatory documents, which either permission an activity or require some form of action to be taken; these are collectively termed Licence Instruments. In addition, inspectors may issue enforcement notices to secure improvements to safety.

No Licence Instruments were issued in the period.