Office for Nuclear Regulation

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Quarterly site report for Low Level Waste Repository Site

1 July 2011 to 30 September 2011


Foreword

This report is issued as part of the Office for Nuclear Regulations (ONR) commitment to make information about inspection and regulatory activities relating to Low Level Waste Repository Site available to the public. Reports are distributed quarterly to members of the Low Level Waste Repository Site Stakeholder Group (SSG) and are also available on the ONR website.

Site inspectors from ONR usually attend Low Level Waste Repository SSG and will respond to any questions raised there by the members of the group. Any other person wishing to inquire about matters covered by this report should contact the ONR.

Email: ONRenquiries@onr.gov.uk
Post: Office for Nuclear Regulation
Redgrave Court
Merton Road
Bootle
Merseyside
L20 7HS

Inspections

The ONR Site Inspector made inspections on the following dates during the quarter:

An ONR Specialist Inspector undertook an inspection focussing on Leadership and Management for Safety on the following dates:

The ONR Project Inspector responsible for oversight of the Decommissioning of PCM facilities met with the licensee on the following dates:

21 July 2011 and 22 August 2011

Routine matters

Inspections at Low Level Waste Repository Site

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

  1. the conditions attached by HSE / ONR 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 licensees 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 inspection of (site/station) covered:

Inspection in relation to decommissioning was undertaken by one of ONR's Project Inspectors and is part of a routine interaction in support of a focussed intervention by ONR. The programme is currently on schedule. LLWR Ltd reported that progress has been made in developing a strategy to manage the disposal of legacy drums that remain on the site.

Inspection of Leadership and Management for Safety found that Control and Supervision of contractors and the management of interfaces between employers are below standard. Some elements of good practice were also observed. Further consideration of the findings of the inspection will be undertaken by ONR to identify what approach will be taken to support LLWR in making further improvements in this area.

Non-routine matters

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

Inspection of incidents on site included following up progress with addressing improvements to maintenance arrangements on site in response to a further event that identified a failure to undertake statutory inspection required under the Pressure Systems Safety Regulations. It is accepted that these failings were linked to the issues currently being addressed to correct existing shortfalls in maintenance activities on the site.

In addition the investigation, by LLWR Ltd, of an event reported under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations that involved a contractor organisation on the site was inspected. It was concluded that LLWR Ltd had undertaken a thorough and comprehensive investigation of the event reported. It was evident that there had been a number of breaches of relevant legislation by the contractor organisation. A letter will be issued to the contractor organisation highlighting the breaches and reminding them of their legal obligations. The ONR site inspector for safety was assured that LLWR Ltd would implement the necessary improvements to minimise the occurrence of events with similar root causes in the future. The inspection confirmed that the implementation of arrangements for the investigation of incidents on the site were adequate.

Regulatory activity

Under health and safety legislation, ONR site inspectors, and other HSE inspectors, may issue formal documents to ensure compliance with regulatory requirements. Under nuclear site licence conditions, ONR issues regulatory documents, which either permit an activity or require some form of action to be taken; these are usually collectively termed licence instruments (LIs), but can take other forms. In addition, inspectors may issue enforcement notices to secure improvements to safety.

No Licence Instruments were issued in the period under report.

News from ONR

ONR Board

The full ONR Board came into effect on 25 July and comprises of nine members: Nick Baldwin as the Chair, four non-executive members (Steve Bundred, John Crackett, Paul Kenny and Kevin Myers) and four executive members (Kevin Allars, Paul Brown, John Seddon and Mike Weightman).

Three Board meetings were held during this reporting period.

Moving towards a programme management organisation

Under the remit of ONR's transformational change programme, work is now underway to establish programme management principles within ONR. This way of working is closely aligned to industry and government programme management best practice and will enable ONR to meet increasing demands. This transformational change will: re-organise ONR's current organisational structure into four delivery-focussed and integrated programmes (Civil Nuclear Reactors, Defence, Sellafield, Decommissioning, Fuel and Waste); establish a corporate programme office to co-ordinate and consolidate information across the programmes, ensuring consistency in operations, and, recruit programme managers to support each of the programmes.

This approach supports the proposed establishment of ONR as a statutory corporation, signalling the ongoing commitment to securing an appropriately resourced and responsive regulator for the future.

ONR public consultation

From 19 Sept 12 Dec a 12-week public consultation is running to clarify ONR's interpretation of bulk quantities relating to radioactive matter. The nuclear site-licensing regime currently applies to a set of defined activities, which includes the storage of bulk quantities of radioactive matter. However, there is no clear definition of what constitutes bulk quantities of radioactive matter, storage of which would need to be licensed.

ONR corporate publications

ONR's first corporate plan for 2011-2015 and quarterly report have been published on the ONR website. The plan provides an insight into ONR's strategic intentions over the next five years and how these will be resourced. The quarterly report reflects the key themes and developments in each of ONR's regulatory programmes and explains the ongoing changes at ONR, as it progresses towards becoming an independent statutory corporation.

Also published on the website in September was the 2011 Nuclear Research Index (safety operating reactors). Traditionally the scope of the NRI is limited to operating nuclear reactors. Research work is done in other nuclear areas, but is coordinated separately. Therefore the scope of the 2011 NRI relates solely to the requirements for nuclear safety research relevant to operating nuclear reactors. ONR is planning to undertake a review to identify the overall requirements for nuclear safety research, including whether it should be extended to cover all areas of nuclear safety research.

Stress tests

The European Council requested a review of safety at European nuclear power plants. The European Commission supported by the European Nuclear Safety Regulatory Group (ENSREG), produced criteria and a plan for this review, now known as the ' EC stress test'. Participating nations agreed to provide progress reports by 15 September and full reports in December. The UK report compiled and delivered by ONR has been published online. 

Fukushima report

Secretary of State for Energy and Climate Change, Chris Huhne, requested a report from chief nuclear inspector Mike Weightman on lessons for the UK nuclear industry from the Japanese incident. The report will be delivered to DECC in the autumn and made public. An interim report was published in May, concluding that there was no reason to curtail nuclear plant operations in the UK. ONR has written to community groups around nuclear sites in the UK to establish levels in interest in ONR conducting a series of regional public briefings.

Site licence application for Hinkley Point C received

ONR received an application from NNB Generation Company on 29 July for a nuclear site licence, relating to its proposed development of a new nuclear power station in Hinkley Point. It is anticipated that ONR will spend around 18 months assessing NNB Generation Company's suitability, capability and competence to install, operate and decommission a nuclear facility. If licensed, the company will be subject to statutory obligations and regulation by ONR.

Nuclear Safety Directive and amended licence conditions

Amendments have been made licence condition 17 and 36 to allow the obligations of the Nuclear Safety Directive (NSD) 2009/71/Euratom, to be fully implemented in relation to Great Britain. In light of this, ONR's licence condition handbook has been updated and is available via the ONR website.