Office for Nuclear Regulation
An agency of HSE

Springfields Fuels Limited Springfields Works report - Q4 2010

Quarterly report for 1 October to 31 December 2010

Foreword

The 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 Springfields Site Stakeholder Group (SSG) and covers activities associated with the regulation of safety at Springfields.  These reports are distributed quarterly.  Site Inspectors of HM Nuclear Installations Inspectorate normally attend Springfields SSG meetings and will be happy to respond to questions raised there or subsequently by members of the Springfields SSG. 

Inspections

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

  • October 5th, 8th & 14th
  • November 9th
  • December 14th

The site inspector also participated in the Site Stakeholder Group meeting, at Westleigh Conference Centre, Preston, on 10th November.

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Routine matters

Inspections at Springfields 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 licensees/operators are 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 Springfields covered a number of areas.

Each NII site inspector has an inspection programme, informed by planned regulatory interventions.  There is currently one key regulatory intervention for this site.  This relates to the treatment of uranic residues, enabling uranium to be recycled and thereby reducing stocks of potentially mobile waste, including encouraging the licensee to continue to refurbish the magnox chemical plants, to allow the recovery of uranic residues, including some enriched residues.  The site continues to report acceptable progress in the processing and recycling of a broad range of operational and legacy uranic residue materials.

Licence condition 11 – Emergency arrangements.  Level One (‘on site’) Emergency Exercise

A team of NII inspectors observed a Level One emergency exercise on 28th September 2010, with a broadly acceptable outcome.  This challenging exercise was conducted by the licensee’s staff, in cooperation with Lancashire Fire & Rescue Service, North West Ambulance Service and Royal Preston Hospital.  The licensee demonstrated the ability to successfully respond to a simulated release from a uranium hexafluoride transport container and the treatment of contaminated casualties, including sending a simulated contaminated casualty to hospital.  NII observed a number of aspects of the exercise, which were generally well demonstrated on this occasion, although NII identified that some aspects of contamination control arrangements on the site could be improved and these were redemonstrated to two NII inspectors, on 6th January 2011, with an adequate outcome. 

Licence condition 21 – Commissioning

Plant inspections were made of the active commissioning of a legacy uranium hexafluoride bottle washing facility and of the inactive recommissioning of the light water reactor fuel assembly plant, both with a broadly positive outcome.

Licence condition 36 – Control of Organisational Change

NII is providing continuing to provide regulatory advice to the licensee, regarding both the adequacy of safety justifications developed by the licensee, relating to a number of planned site organisational changes, together with regulatory advice on the revision of the licensee’s related underpinning arrangements for managing organisational changes.

COMAH Safety Report ‘follow up’ inspections

Following the satisfactory outcome of the overall assessment of the licensee’s revised COMAH Safety Report, a number of ‘follow up’ site inspections continue to be undertaken, primarily by inspectors from HSE’s Hazardous Installations and Field Operations Directorates, with the support of NII specialist inspectors and the Environment Agency site inspector.  A common theme had emerged from these inspections of some variation in the standards across different areas of the site.  Consequently, the licensee is implementing arrangements to promulgate the sharing of ‘best practice’ across the site, as well as responding to the generally minor technical inspection findings, arising from this agreed programme of ‘follow up’ inspections.

In general the arrangements made and implemented by Springfields 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.

Meetings with the Safety Representatives

The site inspector continues to consult with the active site safety representatives.

Meetings between the Department for Transport, the Environment Agency, NII and the licensee

The site inspector continues to participate in periodic meetings involving the Environment Agency, the Department for Transport, the Office for Civil Nuclear Security, NII and the licensee, most recently on 8th October.  The site inspector continues to emphasise the need for the licensee to maintain the ongoing programme of processing the licensee’s legacy stock of uranic residue materials, as well as encouraging the implementation of timely plans, requiring co-operation between the licensee and NDA, to potentially process uranic residues from other sites.  These residues could potentially be processed through the unique uranic processing facilities on the site, providing that this does not lead to a detriment to site safety or to significant environmental waste discharges. 

There continue to be effective working relationships between the regulators, the licensee and the Nuclear Decommissioning Authority regarding Springfields, which the NII regards as a key element of effective regulation.  The ageing but unique and hence very valuable former magnox chemical plant fulfils a nationally important role, in processing a broad range of uranic residues, mainly from Springfields, but also from other sites.  NII remains encouraged that NDA have agreed to fund the operation of this ageing facility for the next two and a half years and have also taken out an option on funding it for a further three years, to potentially process uranic residues from other NDA sites.

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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 response, including actions taken to implement any necessary improvements. NII provided regulatory advice to encourage the licensee to improve plant configuration control, including the use of the licensee’s plant modification control arrangements and the labelling of plant equipment, in response to some minor events in this quarter.

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Regulatory activities

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.

The following site licence condition 3 Consent was issued in this quarter, permissioning the granting of a licence to occupy offices on the site by Advance Uranium Asset Management Limited:

Date Type No. Description
13th December 2010 Consent 514 Licence condition 3 (1) Consent to granting of a licence to occupy office space by Advance Uranium Asset Management Limited.

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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