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West Cumbria Sites Stakeholder Group: Sellafield, Calder Hall and Windscale

Quarterly report for 1 January 2010 - 31 March 2010

The format and contents of this report for the WCSSG are dictated by the range and scope of plants on the licensed sites reported therein and is structured along the following lines:

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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 sites 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 Sellafield, Calder Hall and Windscale.

These reports are distributed quarterly and will be available on the Internet. Site Inspectors of HM Nuclear Installations Inspectorate (NII) attend WCSSG meetings and will be happy to respond to any questions raised there.

1. Introduction

1.1 Proposed Changes to HSE’s Nuclear Directorate

As part of the restructuring of the Nuclear Directorate, to establish it as a Nuclear Statutory Corporation (NSC), a Legislative Reform Order (LRO) needs to be laid before Parliament.  The aim was to lay the LRO in early 2010, with the new body to be established in April 2011.

Unfortunately, given the proximity to a general election, Ministers have decided not to lay the LRO in this parliamentary session.  The LRO has recently been published on the Department of Energy and Climate Change website, and a revised timetable for the introduction of the new body is being developed.

As part of the transition to a Nuclear Statutory Corporation, an Openness and Transparency Project has been set up.  This is to facilitate the ND Management Board’s wishes to be more open and transparent about our regulatory decision making process.

Project Assessment Reports (PARs) are produced to support the granting of Licence Instruments.  As a pilot, executive summaries of these PARs are planned to be placed on the ND website sometime in April.

Given the proximity to a general election, Ministers have decided not to lay the Legislation (known as The LRO), required to establish the Office for Nuclear Regulation, in this Parliamentary session.  This decision has been made to ensure that full and effective parliamentary scrutiny can take place.

Government has recently published for information the legislative documents and the results of the consultation undertaken by the Department for Work and Pensions and the Department of Energy and Climate Change in Summer 2009.  The consultation showed broad support from a wide range of organisations.  The documents can be accessed at:

http://www.decc.gov.uk/en/content/cms/what_we_do/uk_supply/energy_mix/nuclear/new/reg_reform/reg_reform.aspx

The Transition Programme (the work to establish the new organisation) is largely complete and will be placed ‘on hold’ until the point at which the LRO is approved
The planning assumption for vesting date of the new organisation remains 1 April 2011 subject to the LRO passing through the parliamentary process.  The next steps and revised timetable relating to the LRO will in due course be further developed.
In the meantime the work to transform ND into the world leading nuclear regulator fit for future challenges, that we aspire to be, continues with the same drive and determination. 

1.2 Inspections

NII Inspectors made a total of 49 visits to the Sellafield, Calder Hall and Windscale sites during the quarter. This involved a total of 219 person days on site. Issues arising from these and previous inspections will be progressed by NII. The more significant issues identified during these inspections are summarised below.

Routine matters

2.1 Nuclear Decommissioning

2.1.1 Legacy Ponds & Silos (LP&S) Operational Nuclear Safety

We have continued with our programme of planned inspection to gain assurance of Sellafield Ltd’s (SL’s) compliance with licence conditions and key plant specific improvements.  No significant concerns were raised with SL following our inspections.  We also continue to monitor SL’s response to emerging issues and events.  We have had discussions with LP&S senior management regarding lessons learned from the HALES cooling water isolation event (see Section 3.1).

In September 2009 SL reported minor leakage of pond water from the First Generation Magnox Storage Pond via redundant corroded external pipe work.  In February 2010 SL’s successfully completed isolation of the pipe work to prevent further leakage.  We monitored SL’s approach to dealing with this challenge and are  satisfied with their response.

     

2.1.2 Legacy Silos Projects

NII continues to monitor progress made by SL towards retrieval of the inventory from these facilities.  No Licence Instruments were issued this quarter, however, NII is engaged in assessment and inspection of SL’s arrangements for the future permissioning of a number of activities. Of note is the active commissioning of the 3rd Extension Liquor Activity Reduction project in the Magnox Swarf Wet Storage Silo (MSWSS). This is an important hazard reduction project and contributes to the work to prepare the plant for retrieval of the radioactive inventory. While the Inspectorate has not identified any safety case issues with this work, Sellafield has experienced a number of installation and programme issues that have delayed their request for agreement to proceed. The NII has been monitoring this work closely and is now confident that SL will soon be in a position to deliver the work in a safe manner and seek Agreement to progress this hazard reduction.  Also of note is the active commissioning of a new argon passive off gas system in the Pile Fuel Clad Storage Silo (PFCS). NII assessment of the safety documentation and monitoring of SL's progress with this work has provided confidence that the work will be delivered safely and on programme to allow issue of the necessary Licence Instrument (LI). NII has recently discussed the south side air inlets in MSWSS.  SL confirmed installation has commenced, demonstrating progress towards preparation for retrievals in this facility.

2.1.3 Legacy Ponds Projects

We are continuing to monitor SL’s progress in meeting the short term milestones, covering the Pile Fuel Storage Pond, put in place in August 2009 and referred to in previous quarterly reports. SL is making satisfactory progress against the milestones but there is a possibility that specific targets for removing redundant skips from the pond and desludging bays 7-8 could be impacted due to the adverse weather conditions in December.

We have held discussions with SL on the Intermediate Level Waste (ILW) Specification, part 325 (b) relating to the First Generation Magnox Fuel Storage Pond, and we have requested that they provide additional information on remediation progress. The Specification requires that at least 90% of the total volume of potentially mobile ILW accumulated as sludge in the First Generation Magnox Fuel Storage Pond shall be stored in modern stainless steel containment by the 1 August 2010. It is clear that SL will not achieve the Specification requirements by the due date. The additional information will provide an input to our decision making on the regulatory way forward on this issue.

We are continuing to monitor progress on the major construction projects, Sludge Packaging Plant 1 and Local Sludge Treatment Plant. We have not raised any significant regulatory issues relating to these projects over the last quarter.  We also issued an LI (766) permitting operation of the local effluent treatment plant for the Pile Fuel Storage Pond.

2.1.4 Decommissioning Zones 2&3

To carry out decommissioning, SL needs an adequate safety case to show that the work will be done safely. SL's arrangements for safety case production are based on operating plant needs and are not always suitable for decommissioning purposes. We have been discussing this issue with SL pointing out some of the difficulties we have had with some decommissioning safety cases. SL now intends to trial some changes to the current safety case process to develop improved arrangements for the production of decommissioning safety cases. A possible outcome is a pragmatic safety case, which addresses the safety and environmental challenges encountered during decommissioning, but enables a decommissioning job to begin without unnecessary delays arising from the safety case process.

2.1.5 Windscale

Further concerns have been raised with SL Windscale on the implementation of its LC36 (Control of Organisational Change) arrangements particularly in relation to the management of the Management of Change Assessment (MOCA) processes, the management of the Windscale Site Baseline (Resources) documents and the management of resources across the site. Further meetings are envisaged to discuss the Sellafield Ltd Windscale proposals to address the issues raised.

Various discussions and visits were undertaken during the report period relating to the progress made by SL Windscale on the decommissioning project work across the Windscale Site e.g. Piles 1 & 2, Windscale Advanced Gas Cooled Reactor (WAGR) and Redundant Post Irradiation and Examination (PIE) Facility. During the period SL Windscale completed Campaign 9 of the WAGR Decommissioning Programme i.e. the removal of the reactor vessel.

As reported in  previous reports, SL Windscale placed an embargo on the movement of radioactive material movements within the Active Handling Facility following a number of events associated with the breakdown in the material movement control processes. Movements of material within, and in and out of, the facility have now been restarted following the introduction of revised “best practice” procedures for the control and movement of radioactive material and a programme of work to make specific improvements within particular caves. NII has undertaken initial inspections of the revised processes, and will continue with further inspections over the next few months. NII also continues to engage with SL Windscale on the various projects within the Active Handling Facility Integrated Safety Improvement Programme which are ongoing.

2.1.6 Separation Area Ventilation Project

The main elements of the Separation Area Ventilation Project i.e. the main plant room and stack, are in the early stages of construction. The project is on programme and in the last quarter construction of a new sub station and the foundations for the main plant room commenced.

Calder Hall

There is nothing to report this quarter.

2.2 Site wide matters

2.2.1 Lifetime Plan

NII has inspected parts of the Lifetime Plan review process that SL and NDA are applying to define the final contractual basis for measuring progress with decommissioning legacy facilities.  NII is aiming to confirm the adequacy and integrity of the Lifetime Plan (LTP10) and build confidence that it represents a robust programme of work that SL can deliver.

We are satisfied with the planning process, but both NII and EA are concerned about the deferral dates for some facilities.  LTP10 will provide a contract baseline between SL and the NDA, however it will not be a plan we can accept.  The Integrated Change Programme (ICP) will therefore be vital in bringing these dates forward.

As we mentioned in our previous report, we plan to regulate decommissioning projects utilising SL’s revised LC 35 (Decommissioning) arrangements.  We have worked with SL on the development of these arrangements, and we hope to formally Approve the principles associated with these arrangements in the near future.  The principles will include the identification of Key Milestones by SL, and a change process associated with these Milestones.  Should a Key Milestone go back, and SL is unable to demonstrate via the change process that all that is reasonably practicable has been done to meet the existing Milestone, then NII may take enforcement action.

2.2.2 Integrated Change Programme (ICP)

We continue to monitor this programme through the monthly ICP Forum.  At the February Forum, both NII and EA  expressed concern about lack of the visibility of delivery, which did not provide us with the confidence we required.  At the Forum in March SL provided a lot of very useful information on the work being undertaken in the high hazard areas, but we need further evidence to give us confidence that the ICP will deliver the accelerated hazard reduction we seek.  SL has agreed to provide further evidence at the next Forum.

In support of our work on projects associated with the ICP, one NII Inspector and a member of the NDA accompanied SL staff on a visit to Savannah River in USA.  Our Inspector found the visit to be most helpful, as he saw at first hand the results of “Roll back”, Disciplined Operations  and “Projectisation” which are initiatives that SL wishes to introduce at Sellafield.

2.2.3 Emergency arrangements

As part of our work to formally Approve the proposed joint Sellafield/Windscale Emergency Plan, NII inspectors observed an exercise involving an event on Windscale.  NII concentrated on the interactions between Sellafield and Windscale staff, which NII found to be satisfactory.  NII will now discuss changes to the Emergency Handbook, (which underpins the Plan), with Sellafield and Windscale Emergency Planners with the aim of Approving the Plan later in the year.  NII has also undertaken work on Severe Accident Management Strategies (SAMS).  These are documents that give guidance to operators on how to deal with the most infrequent severe accidents ie much less frequent than design basis accidents.  Over the past three years NII has been encouraging SL to introduce these documents, but progress has not been good and commitments have not been met.  Sellafield Ltd is now developing a resourced improvement plan, the delivery of which will be monitored by NII.

2.2.4 Maintenance Intervention

The Maintenance Re-Engineering Programme (MRP) is SL's initiative to improve delivery of Maintenance & Asset Care at Sellafield over a number of years NII recently wrote to Sellafield Ltd indicating our continued support for the MRP.  Our letter also identified a number of areas where maintenance and asset care could be improved on the site. SL confirmed that these areas will be addressed via the MRP. NII  expects to receive a programme for this work (identifying target dates for completion of Key Milestones) during the next quarter.

2.2.5 Alarm Management

It is considered that ND’s intervention has raised the profile of the importance of alarm management to nuclear safety amongst senior management at SL.  This is evidenced through the establishment of “Alarm Review Groups” in some facilities, that are delivering against defined improvement plans, and the licensee’s approach to Conduct of Operations (Disciplined Operations).  This is enabling SL to provide better control and oversight of alarm management across the site.

2.2.6 Improvements to LC 22 (Modifications) arrangements

Discussions are continuing on the efficacy of the current SL arrangements for the modification of plant.  The emphasis is on SL developing adequate arrangements to ensure appropriate engagement with all modification proposals that could have a significant off site nuclear safety impact.

2.2.7 Solid Waste Management Inspection

During 2010 there is to be a series of small inspections  carried out jointly with the EA to review the current capability of SL to safely manage and where possible dispose of solid radioactive waste.

As part of this work, an inspection was undertaken in February on Plutonium Contaminated Material (PCM).  The inspection also reviewed progress against LI Specification 326b on PCM and against the recommendations made following a larger inspection in 2006.

This particular inspection covered the plutonium contaminated waste production, treatment and storage. Disposal is not currently possible within this area as the wastes are above the acceptance criteria for the LLWR.  SL was very helpful, open and transparent in supporting the inspection, supplying photographs and information.

Key findings were

• Positive participation from SL staff at all levels.
• Staff enthusiastic and geared to a waste management mission.
• Some of the older legacy building waste had gone or was on the point of going to modern facilities, which is an improvement over the 2006 situation.
• Some of the issues raised in 2006 had still not been addressed.  We are to meet with SL to discuss how the recommendations from an EA report in 2006 can be closed out

A further inspection on ILW waste management is to take place in May/June 2010

2.2.8 Sellafield contaminated land & ground management

SL has presented to NII a summary of the current status of the contaminated land and groundwater management programme.  This included a brief overview of the entire project from its inception to the current status,  some of the findings, and the proposed way forward which we understand will be presented to stakeholders.   NII is satisfied that this programme of work is progressing satisfactorily.  We will be engaging with SL and working closely with the EA with regard to borehole monitoring and maintenance requirements.

2.2.9 Baseline surveys

NII is very supportive of the recent SL initiative to introduce baseline surveys of the site.  These surveys will identify and catalogue leakages of radioactive material outside buildings on the site.  Most leakages are likely to be historical, and will already have been recorded and managed.  SL is regularly updating NII and EA as the survey work progresses and NII is in correspondence with SL on the need for improvements to LC34 (Leakage and Escape) arrangements.

2.2.10 Radioactive Substances Act Authorisation

NII has responded to EA on their Consultation Documentation for the proposed changes to the SL and Windscale Sites Discharge Authorisation NII is supportive of the changes.  We are currently studying the resultant Decision Documentation, which is produced following the public consultation and will be replying to the EA shortly.  It is unlikely that our views will change from those expressed by us at the Consultation Stage but clearly we are currently reserving our position.

2.2.11 Periodic review of safety cases

Following difficulties in maintaining its programme of periodic reviews of safety cases, SL has revised its arrangements under LC15 to streamline and improve interactions with NII. We have Approved the part of the revised arrangements that requires ten-yearly reviews and requires any changes to the arrangements to be consistent with NII guidance.

2.3 Operations

2.3.1 Magnox Operations

Our principal inspection in the Magnox plants during the quarter was to judge SL’s compliance with Licence Conditions 23 and 24, entitled respectively Operating Rules (ORs) and Operating Instructions (OIs).  We did not attempt to address every duty specified or implied by those conditions: we chose to concentrate on ORs, and specifically on how they are derived from safety cases, how they are expressed, and how SL ensures and records compliance with them.  Findings are being progressed with SL.

                                                                                                   

2.3.1.1 Magnox East River

The Transit Flask Maintenance Facility in the Fuel Handling Plant (FHP) allows light maintenance on flasks that convey spent Magnox and AGR fuels to and from FHP. Flasks must be empty before they are maintained, to avoid exposure of workers to high radiation dose rates.  We have assessed SL’s proposal to modify the safety measures that help prevent such exposures, and have issued an LI (769), allowing the facility to return to service.

The AGR Ramp Bogie Winch Room in FHP contains machinery that hauls skips of AGR fuel into and out of the fuel storage pond.  We have assessed SL’s proposal to improve the measures that prevent entry to this room while radiation dose rates inside it are high, and have issued an LI (771) giving permission for the modification.

2.3.1.2 Reprocessing Operations

Last year we reported that a small leak of radioactively contaminated water from a ventilation condensate pipe was repaired; ground beneath the pipe had been contaminated and needed to be cleaned up.  No immediate regulatory action was judged necessary then, but because the incident revealed a number of deficiencies the EA and NII have worked together to investigate the incident and consider regulatory action.  In this quarter HSE has written to SL requiring it to rectify its compliance with the Ionising Radiations Regulations 1999, and LC34, leakage and escape

2.3.1.3 Plutonium Finishing and Storage

Periodically, SL is required to review its safety cases.  We have continued our assessment of its last review of the safety case for the plutonium finishing plant by inspecting how air filters containing plutonium are changed.  By inspecting similar operations in other plants at SL we have seen how it might be done more safely, and we have asked SL to identify and make reasonably practicable improvements on the plutonium plant.

With the EA, we have inspected the extent to which SL has learned the lessons from a number of contamination events in these plants over the last two years.

We continue to monitor SL’s progress in improving the safety of how operations are conducted in these plants, which have provided a pilot for a new standard for the conduct of operations across the site.

NII carried out a readiness inspection in preparation for the next phase of the Stores Inventory Removal Project (SIRP), concentrating on training, supervision and documentation. We observed the entire can retrieval process on the SIRP simulator and found the training to be of a good standard. The operators confirmed that they were satisfied with the SIRP training and the SIRP DAPs and members of the team clearly understood their roles and responsibilities. NII examined samples of the training records for the SIRP DAPs and operators and also the relevant work instructions and associated documentation and these were found to be adequate.

This phase of the SIRP is driven by both security and safety imperatives and involves the removal of a large number of cans over a 12 month period from stores which are currently considered inadequate to locations which are considered to meet modern standards.  Earlier work involving the movement of a large number of cans between stores was successfully completed in October 2009. NII did not identify any significant issues that would require the next phase of SIRP operations to be delayed and so an LI (763) was issued in January for can transfers to proceed.

2.3.2 THORP (Thermal Oxide Reprocessing Plant) Operations

During this reporting period, NII undertook routine inspections on the emergency arrangement for AGR Storage Pond and LWR Storage Pond. There have also been follow-up inspections in relation to nuclear fire safety issues, and meetings covering a variety of topics including assurance arrangements, risk management and pond furniture projects.

SL monitors pond parameters such as level and temperature although at present these parameters have not got a nuclear safety designation. SL will change this designation at the next safety case review for these ponds.

SL has made reasonable progress in addressing the nuclear fire safety issues raised by NII over 18 months ago. However there are still significant improvements to be made especially in relation to addressing the known defects of fire dampers on THORP.

Two LIs have been issued. The first granting an agreement to operations of the MEB export facility and interim store (765), and the second an agreement to the overarching strategy proposed by SL to prove the safety and efficacy of nitrate dosing the THORP Receipt and Storage Pond in order to prevent fuel corrosion (764).

NII continued to track progress of the THORP Long Term Periodic Review versus the Improvement Notice and this remained on programme to deliver within the timescale of December 2010.

2.3.3 High Level Waste Plants Operations

2.3.3.1 Highly Active Liquor Evaporative

• Evaporator A: During this quarter the evaporator processed Magnox liquors until late February when operation was suspended when routine cctv monitoring identified a leak in a water line into the vessel. Following technical assessment, SL decided to recommence processing and the batch should be completed in April. SL is currently considering how best to proceed once the current batch is completed.
• Evaporator B: The planned engineering work is ongoing and the unit should be available for duty in summer 2010. Following the finding on evaporator A, discussed above, the analogous water wash line on this evaporator was inspected and found to have a pinhole leak. Options regarding repair are currently being investigated.
• Evaporator C:  At the end of March, NII issued an LI (767) to permission processing of up to 1000 tonnes of Oxide fuel and the remainder of the Magnox fuel.

2.3.3.2 HAL Stocks

NII is still working with SL on revisions to the HAL Stock Specification No 679.  The revisions are required to ensure that the Specification is appropriate for the storage of the less active liquors that are likely to arise during the post operational clean out of the plant.

2.3.3.3  Waste Vitrification Plant (WVP)

Last year, NII permissioned the operation of WVP Line 3 under enhanced administrative controls, pending the completion of engineering improvements.  This permission was time based and expired on 31 March 2010.  NII assessed the safety case, submitted by SL to continue operation of Line 3, and found it to be inadequate.  Line 3 operations will therefore not now recommence until NII has received and accepted an adequate safety case.

2.3.3.4 Residue Export Facility (REF)

During this quarter the first exports of vitrified residues were successfully returned to Japan and Holland.

2.3.4 MOX Operations

Discussions were held concerning the forward work programme and proposed modifications to the facility to improve reliability and throughput.

An inspection of the MOX facility revealed no significant issues although some minor recommendations have been made that SL is addressing.

Three of our Inspectors, together with SL staff, visited the MELOX plant in France. The purpose of the visit was to understand the processes used in France for rod fabrication, as SL is planning to utilise some of these processes at SMP.  Our Inspectors found the visit helpful, and it will assist us in our assessment of future SL submissions.

2.3.5 Infrastructure Operations

Various inspections, discussions and visits have been undertaken during the report period on various aspects of the operations managed within the Infrastructure Directorate. Topics covered during this report period included the implementation of the Analytical Services Building Continued Operations Safety Report (COSR), the development of a strategy to deal with the bottles of analytical waste residues currently stored throughout the Analytical Services Building and the ongoing improvements within the Laundry & Change-room facilities on the site. NII has also participated in the ongoing discussion between SL and the Competent Authority (HSE Hazardous Industries Division/Environment Agency) on the status of the Sellafield Site with respect to the COMAH regulations.

2.4 Major projects

2.4.1 Sellafield Product & Residue Store (SPRS)

Performance-based commissioning is complete and Level 3 Commissioning is on target for completion by end April 2010. There is some slippage in answering the issues raised during the Pre-Inactive Commissioning Safety Report but the SL is planning to have provided answers to all the issues prior to the Pre-Active Commissioning Safety Report.

3.0 Non routine matters

3.1 Highly Active Liquor Evaporation and Storage (HALES) Disruption of Cooling Water Supply 22^nd January 2010

The HAST tanks experienced a loss of cooling water incident on 22 January.  A similar incident involving a loss of cooling water occurred on 1 April 2009.

NII is continuing to investigate the more recent incident in line with HSE guidance, and formal statements have been taken.  NII intends to use the current investigation to ensure that SL implements the learning from both events.

A number of issues have emerged from the investigation to date and one of particular concern is the training of Nominated Persons - Process Plant and Equipment Isolations (PP&EI). These are staff authorised to isolate plant and equipment.

Shortcomings in the training of these Nominated Persons were such that NII was of the opinion that SL was in contravention of Licence Condition 10 (Training), in that it had failed to make adequate arrangements in the HAL plants for the suitable training of Nominated Persons (PP&EI) who have responsibilities for operations which may affect safety. In order to formalise the process of compliance with SL’s statutory duties, an Improvement Notice (reference NH001/2010) was issued on 4 March 2010, requiring SL to remedy the contraventions by 18^th June 2010.

 

4.0 Regulatory activity

Table 1

Consents, approvals, specifications and enforcement actions
Issued during the quarter

1 January 2010 to 31 March 2010

Date	Type	Ref. No.	Description
Sellafield Ltd - Sellafield (and Calder Works) – Nuclear Site Licence no. 31G
4/03/2010	Improvement Notice	NH001/2010	Sellafield Ltd failed to make adequate arrangement in HALES for the suitable training of persons appointed as nominated persons (Process Plant and Equipment Isolations) who have responsibility for operations which may effect safety
24/03/2010	Approval	768	Approval of changes to the arrangement for  Periodic Safety Review
Sellafield Ltd – Windscale – Nuclear Site Licence no. 83
NONE

Table 2

Agreements & acknowledgements issued by nii during the quarter

1 January 2010 to 31 March 2010

Date	Ref. No.	Description
Sellafield Ltd – Sellafield (and Calder Works) – Nuclear Site Licence no. 31 G
12/02/2010	763	Agreement to proceed with PFS/0381 – assessment of the impact of gloop on the restart of SIRP operations on stores 1-4 under the implementation of OSM (CULT 11843)
02/03/2010	764	Acknowledgement – Request for acknowledgement of receipt of safety documentation for overarching strategy paper for sodium nitrate dosing of THORP receipt & storage ponds
01/03/2010	765	Agreement to operate the MEB export facility and MEB interim store
30/03/2010	766	Agreement to commence operations of the Local effluent treatment plant (LETP).
10/03/2010	767	Agreement to commence modification to an existing plant – Operation of evaporator “C” under the revised safety case (PMP HALES) December 2009
17/03/2010	769	Acknowledgement – Receipt of Safety Documentation for the Transit Flask Maintenance Facility
26/03/2010	771	Acknowledgement – Fuel Handling Plant: AGR Ramp Bogie Winch Room Interlock Upgrade
29/03/2010	772	Agreement to Proceed with Implementation of PFS/0397 – Rotary Vacuum Filter table Refurbishment and Implementation of radiological operational Safety memo cult No 13434
Sellafield Ltd – Windscale – Nuclear Site Licence no. 83.
NONE

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