Office for Nuclear Regulation
An agency of HSE

Capenhurst (Urenco UK Limited) report - Q4 2010

NII site inspector's quarterly report to the local stakeholder group for 1 October – 31 December 2010

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. 

Inspections

Nuclear Installations Inspectorate (NII) inspectors made on the following dates during this quarter:-

  • October 4th, 5th, 7th & 13th,
  • November 2nd, 4th, 18th & 26th,
  • December 1st, 8th & 16th

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Routine matters

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

  1. the conditions attached by HSE/NII to the nuclear site licence;
  2. the Health and Safety at Work etc Act (HSWA) 1974 and
  3. 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 licensee’s actions on the site in relation to incidents, operations, maintenance, projects, modifications, safety case changes and any other matters which may affect safety.  The licensee is required to make and implement adequate arrangements under the conditions attached to the licence in order to ensure legal compliance.  Inspections seek to judge both the adequacy of these arrangements and their implementation.  In this period routine inspections of the site covered a range of areas.
Each NII site inspector has an inspection programme, informed by planned regulatory interventions.  There are four 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 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).

Licence Condition 14 – Safety Case Documentation

Two NII specialist safety case assessment inspectors conducted an inspection of the licensee’s safety case production and implementation processes, on 27th to 29th July, with a positive outcome.  The NII assessment of the licensee’s Tails Management Facility ‘pre commencement’ safety cases for a uranium oxide store has continued in this quarter, with a number of regulatory issues being raised by NII, regarding the adequacy of the proposed store design and the integrity of long term U3O8 powder storage in painted mild steel containers.  Both of these regulatory issues are awaiting further responses from the licensee.  The licensee has provided generally timely responses to the technical issues raised during NII assessment by specialist inspectors.

Licence Condition 19 - Construction of installation of new plant.  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 has expressed strong support for the timely construction and operation of the Tails Management Facility, (as this should lead to a significant medium term reduction in the hazard associated with the storage of uranium hexafluoride on the licensed site).  HSE’s Hazardous Installations Directorate (HID) is separately currently assessing the licensee’s application for the necessary hazardous substances consent, on behalf of the local planning authority, as well as having recently completed the assessment of the related COMAH safety report, sent to HID in November 2009.  Constructive meetings have been held with both the licensee and 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 Bootle on 6th December.  Regulatory advice has also been provided to the licensee, to ensure that adequate control and supervision of all safety related aspects of the TMF project, including the construction work, is adequately implemented by the licensee’s organisation.

Licence Condition 32 – Disposal of radioactive waste.  Integrated Waste Strategy

Following the provision of earlier regulatory advice from NII and the Environment Agency, NII is awaiting receipt of the finalised Integrated Waste Strategy from the licensee.

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 significant regulatory assessment, as the licensee’s workforce reduction proposals were clarified and reductions were implemented, throughout 2009 and 2010. 

Throughout this quarter, an NII specialist organisational change assessment inspector has continued to provide regulatory advice to the licensee regarding proposals to integrate the supervision arrangements for two of the enrichment facility’s shift teams, including discussions with the affected staff, as well as by conducting sampling assessments of the licensee’s developing organisational change safety documentation.  NII has also assessed aspects of the implementation of the licensee’s underpinning organisational change arrangements.  NII has provided extensive regulatory advice to the licensee, rehearsing the expectations of NII, in order to ensure that the licensee appropriately addressed all key safety aspects of the organisational changes, which were subject to permissioning by NII.  This was to ensure that the implementation of the licensee’s proposed staff reductions retained adequate organisational resources and the full range of experience and competencies required of a nuclear licensee. 

In general, the arrangements made and implemented by the licensee in response to safety requirements were deemed to be adequate in the areas inspected. However, where improvements were considered necessary, satisfactory commitments to address the issues were made by or are being sought from the licensee, and the site inspector will monitor progress during future visits.  Where necessary, formal regulatory enforcement action will be taken to ensure that appropriate remedial measures are implemented to reasonably practicable timescales.

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 2009, some unexpectedly variable levels of neutron radiation were measured, at the boundary of the Urenco UK Limited licensed site, at levels still well below any statutory limits and which are not judged to represent a significant health and safety risk, but nevertheless warranting further investigation.  Further independent measurements, taken by the Health Protection Agency, are periodically completed.  This has initiated ongoing assessment and research into neutron dose measurements by both Capenhurst licensees, led by Urenco UK Limited, 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 enthusiastic and active team of safety representatives, most recently at a meeting with the safety representatives on 1st December, as well as during plant inspections.  The work of the safety representatives continues to make a valuable contribution to the site safety culture.

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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/operators response including actions taken to implement any necessary improvements.

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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 requires some form of action to be taken; these are collectively termed Licence Instruments (LI). In addition inspectors may issue enforcement notices to secure improvements to safety. An executive summary of the internal ND report, supporting the issue of any Licence Instruments or site licences by ND, is published on the HSE website.

No Licence Instruments were issued during this quarter.

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Transforming HSE Nuclear Directorate

HSE’s Nuclear Directorate (ND) continues work on a programme of change entitled 'Transformation', which is intended to help ND realise its aims to become recognised as a world-class regulator. Over the coming months, ND’s focus will include improving the way it engages with all of its stakeholders, including communities around nuclear licensed sites, to explain the work that it does and the regulatory decisions it makes. 

ND will keep stakeholders fully informed of changes and any decisions that are made through channels including:

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Updated 17.08.11