Office for Nuclear Regulation

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Springfields Fuels Limited Springfields Works report - Q1 2011

Quarterly report for 1 January to 31 March 2011


Foreword

The report is issued as part of the Health and Safety Executives 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 Fuels Limited. These reports are distributed quarterly and are also available on the HSE's web site at http://www.hes.gov.uk/nuclear/llc/index.htm. Site Inspectors of HM Nuclear Installations Inspectorate usually attend Springfields SSG meetings and will respond to questions raised there by members of the Springfields SSG.


Inspections

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

Two NII inspectors also participated in the licensees Emergency Planning Consultation Committee meeting at Lancashire Constabulary HQ at Hutton on 1st March.

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Routine matters

Inspections at Springfields Fuels Limited 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

egulations 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.

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.

In this period routine inspections of Springfields Fuels Limited covered:

Incidents on the site

Meetings have been held with the licensees Directors, providing regulatory advice, to ensure that the licensee fully implements the range of lessons learned from a series of minor events on the plants, which occurred during the very cold weather at the end of 2010. The site inspector wrote to the licensee explaining the importance of implementing the wider lessons from these minor events and an acceptable forward programme of improvements has been agreed with the licensee.

Emergency arrangements

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 licensees 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 that 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 a broadly acceptable outcome. Following this emergency exercise, NII provided regulatory advice on the need for the licensee to further develop aspects of the radiological contamination control arrangements, to which NII has received a positive response from the licensee. The licensee has encouragingly developed an agreed protocol, with the relevant off site authorities, to expedite the treatment of potentially contaminated casualties from the Springfields site, as a contingency plan. Regulatory advice has been provided in this quarter, to enable the licensee to further enhance the on and off site emergency plans.

Commissioning

A plant inspection was made of the inactive recommissioning of the light water reactor fuel assembly plant, with a very positive outcome. The licensee was found to be setting appropriately high standards for the conduct of operations at this facility, with due attention being paid to safety matters.

Control & Supervision of Operations

Plant inspections were made of the licensees control of plant operations in several areas of the Oxide Fuels Complex, with an acceptable outcome.

Control of Organisational Change

NII has continued 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 licensees related underpinning arrangements for managing organisational changes, to incorporate modern best practice.

COMAH Safety Report follow up inspections

Following the satisfactory outcome of the overall assessment of the licensees revised COMAH Safety Report, a number of follow up site inspections have continued to be undertaken in this quarter, 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 site inspections.

In general the arrangements made and implemented by Springfields Fuels Limited 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, including during NII plant inspections.

Springfields Site Stakeholder Group meeting

The site inspector participated in the special meeting of the Springfields Site Stakeholder Group, held at site on 4th March, to discuss the licensees emerging proposals for the future on site disposal of solid very low level radioactive waste, including a visit to the proposed site location.

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. The site inspector continues to emphasise the need for the licensee to maintain the ongoing programme of processing the licensees legacy stock of uranic residue materials, where the licensee continues to report acceptable progress, as well as encouraging the implementation of timely plans, requiring co-operation between the licensee, the NDA and other site licensees, 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 years and have also implemented an option for funding it for a further three years, to potentially process and recycle 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 licensees 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 licensees plant modification control arrangements and the labelling of plant equipment, in response to some minor events in this quarter.

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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 internet at web address http://www.onr.org.uk/pars/index.htm. No licence instruments were issued in this quarter.

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Office for Nuclear for Regulation - 1st April 2011

Following an announcement on 8th February 2011, the Government intend to bring forward legislation to create a new independent statutory body, outside of the HSE, to regulate the nuclear power industry. The new statutory corporation shall be known as the Office for Nuclear Regulation (ONR) and will take on the relevant functions currently carried out by the Health and Safety Executive and the Department for Transport.

The ONR will be a new independent regulator, formally responsible in law for delivering its regulatory functions. The creation of the ONR will consolidate civil nuclear and radioactive transport safety and security regulation in one place.
The proposal will not affect the current regulatory requirements or standards, with which industry must comply, and the vast majority of the costs of the regulator will continue to be recovered in charges from operators in the nuclear industry, rather than funded by the public purse. Additional organisational costs will be entirely met by the nuclear industry.

Pending the legislation, the Health and Safety Executive has taken steps to establish the ONR as a non-statutory body from 1st April 2011, signalling our commitment to securing an appropriately resourced and responsive regulator for the future challenges of the nuclear sector. The Government will review the functions and processes of the interim body in order to inform its planned legislation.
Following this announcement, work is ongoing within Nuclear Directorate to implement the move to ONR. However, business as usual remains unaffected. If you have any further questions, please contact onrenquiries@onr.gov.uk

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