Office for Nuclear Regulation

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Springfields Fuels Limited Springfields Works report - Q3 2011

Quarterly report for 1 July 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 the Springfields Fuels Limited site available to the public. Reports are distributed quarterly to members of the Springfields Site Stakeholder Group and are also available on the ONR website.

Site inspectors from ONR usually attend the Springfields Site Stakeholder Group 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 nominated Site Inspector and other ONR inspectors made inspections on the following dates during this quarter:

An ONR emergency arrangements specialist inspector also provided regulatory advice at the licensees Emergency Planning Coordination Committee meeting at Lancashire Constabulary HQ, Hutton on 28th September.

Routine matters

Inspections at Springfields Fuels Limited

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.

ONR assessment of safety related changes to the licensees organisation

Following further interactions with the licensee, including the provision of regulatory advice, ONR continues to conclude that the licensee had adequately applied the appropriate management of organisational change arrangements to these proposed changes.

Level One (on site) emergency exercise observed by ONR

A team of five ONR inspectors observed a suitably challenging Level One (on site) emergency exercise on 8th September, based on a criticality safety scenario, with several casualties The exercise was assessed as meeting the standard expected by ONR for a demonstration of the licensees emergency arrangements. A number of relatively minor opportunities for improvement were communicated to the licensee, for which a response to ONR has been requested by the end of November.

Meetings to review the licensees progress with the processing of legacy and operational uranium residues

The ONR site inspector has continued to meet with the licensee to review the licensees progress with the processing of both legacy uranium residues and operational uranium residues arising from site operations. The licensee continues to report generally good progress with the processing of a broad range of residues and the recycling of much of the uranium from within the residues.

Annual review of safety & environment

The Annual Review of Safety & Environment meeting was conducted between ONR, the Environment Agency and the licensee on 8th July 2011. Constructive and generally very positive discussions were held, whilst reviewing the licensees performance over the period April 2010 to March 2011. Two plant inspections were also made following the meeting, with a positive outcome, the licensee demonstrating appropriate control of the nuclear safety of plant operations.

Inspection of the licensees safety case implementation

ONR recently reviewed the number and safety categorisation of the licensees safety cases, across the licensed site. On the basis of this review, ONR concluded that a limited increase in ONR site inspection of the licensees compliance with the requirements of these safety cases was warranted. Consequently, some additional themed compliance inspections have been initiated. Due cognisance was paid, during discussions with the licensee, to avoid duplication in regulatory inspection, by HSE-HID of the COMAH Safety Report, (Springfields being a top tier COMAH site) and by ONR of the nuclear safety cases. The initial results of these additional site inspections are providing a suitable degree of regulatory reassurance that the licensee is generally achieving compliance with the stringent requirements of the licensees nuclear safety cases. ONR provided the licensee with written regulatory advice following these inspections, summarising the inspection findings. These emerging inspection findings will inform future ONR site inspection planning.

Fire safety inspection.

An ONR fire safety specialist inspector inspected the site on 1st September, reviewing arrangements and inspecting a sample plant, with a generally adequate outcome.

Meetings with the safety representatives.

Meetings are routinely held with the licensees active team of safety representatives, including during plant inspections. The safety representatives continue to make a valuable contribution to the site safety culture.

In general, the arrangements made and implemented by the site 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 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.

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.

The licensee continues to promptly report minor events to ONR, which are investigated by the licensee, in accordance with the licensees arrangements. These arrangements were deemed to be adequate, following an ONR inspection on 4th August, to follow up a minor event involving the failure of an air compressor hose.

There were no matters of note to report.

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, but can take other forms. In addition, inspectors may issue enforcement notices, to secure improvements to safety. No licence instruments were issued in this quarter.

Reports detailing regulatory decisions can be found on the ONR website.

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. Further information about the Board and minutes of the meetings can be found under the Board pages of the ONR website.

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.

ONR Nominated Site Inspector Nuclear Safety.
Office for Nuclear Regulation.
October 2011.