Health and Safety
Executive / Commission
Nuclear
LLC reports
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 Dounreay Local Liaison Committee (LLC) and covers activities associated with the regulation of safety at Dounreay. These reports are distributed quarterly. Site Inspectors of HM Nuclear Installations Inspectorate attend LLC meetings and will be happy to respond to any questions raised there. Any other person wishing to inquire about matters covered in this report should contact the HSE, Nuclear Directorate Information Centre on 0151 - 951 - 4103.
1. The Site Inspectors visited Dounreay on the following days:
14 - 18 January 2002 - Site Inspection2. NII met with UKAEA in Edinburgh on 5 March regarding changing the site boundary to accommodate the building of shaft waste retrieval facilities.
3. NII, SEPA, Scottish Executive, and Highland Council met UKAEA in Inverness on 24 January to discuss UKAEA proposals for public participation in the Dounreay Site Restoration Plan.
4. A number of video conferences took place with UKAEA regarding:
6. The main thrust of NII activity during the period of this report has been associated with preparation for the team inspection of maintenance, site infrastructure matters, development of the fuel management strategy, ventilation improvements, development of modern standard safety cases and liaison with SEPA and other government departments.
7. Inspection of the Dounreay site has continued as planned during the quarter.
8. The annual Level 1 emergency exercise will be held on 22 May. An NII inspector from the MOD Division will be attending to observe the interaction with Vulcan NRTE. The Dounreay site inspector has been invited to observe the Vulcan level 2 exercise in November 2002. 9. Following a move to offsite car parking, NII ascertained that no formal risk assessment had been carried out on the effect on emergency evacuation. A UKAEA internal investigation, requested by NII, confirmed that UKAEA procedures had not been followed and a UNOR has been raised. There were also a number of significant conventional safety hazards that had not been considered and FOD was informed. HSE ensured that urgent action was taken by UKAEA to attend to these matters.
10. The review took place on 29 November and the actions that were placed on UKAEA are being monitored by the site inspectors. Progress has been generally satisfactory apart from the action to undertake a stress risk assessment where UKAEA has not yet implemented the project. NII has again emphasised to UKAEA the importance of this matter and awaits a reply.
11. The final audit report was published on 22 January 2002. The work on twenty-seven recommendations will still take several years to complete and they have been placed on a medium term programme. UKAEA produced the Dounreay Site Restoration Plan (DSRP) to address a further twenty seven recommendations which are strategic in nature and which have very long completion timescales. Progress in achieving key milestones on the programmes derived from the DSRP will be monitored by day to day inspection and twice yearly formal progress meetings. An annual progress report will be provided to the Liaison Committee after the November DSRP progress meeting.
12. Discussions were held in January 2002 with UKAEA, SEPA and Highland Council on various aspects of public consultation for the DSRP. UKAEA informed those present that it wishes to trial the consultation process on proposals for dealing with contaminated solvents and oils. The project will be regulated by NII and SEPA under normal regulatory compliance procedures.
13. NII and SEPA met UKAEA to progress the development of the fuel management strategy. The emerging strategies for the individual fuel liabilities and the implications for plants such as D1208 and D1203 were discussed. The baseline strategy is to remove as much of the material from the site as possible and interactions with other sites were discussed. Meetings will continue and become more detailed as implementation of the strategy develops.
14. Progress with the development of safety cases will be discussed at the twice yearly DSRP meetings between the regulators and UKAEA as mentioned in section 11 of this report. A project has been initiated by UKAEA to improve the management of development of safety cases and this will be monitored by NII under UKAEA's arrangements for complying with Licence Condition 36.
15. UKAEA has proposed a phased restart of D1208 operations and therefore NII are seeking information on the forward operations programme and its linkage to the programme of engineering improvements. However, a number of UKAEA procedures for implementing MSSC's are still being developed.
16. The first in a series of meetings on UKAEA's proposals for operating D1203 to recover unirradiated enriched uranium was attended. Information was obtained on the options considered by UKAEA for dealing with enriched uranium material at Dounreay and on the justification for operating D1203. UKAEA agreed to produce an optioneering paper for treatment of the material. A MSSC is also being produced.
17. NII and SEPA have continued to discuss with UKAEA progress on audit recommendation 80 related to UKAEA's review of it's options for the storage and disposal of LLW including the disposal of LLW to Drigg. UKAEA considers that liaison with Drigg is well advanced and that an application for a transfer authorisation will be sent to SEPA in April 2002. SEPA will then carry out a public consultation exercise that will take about nine months to complete.
18. It was reported in the last quarter that NII awaited a reply to letters to UKAEA regarding significant concerns that certain projects in the FCA were not following the UKAEA arrangements for licence compliance. A reply has been received in which UKAEA agreed to undertake awareness training for appropriate personnel. NII will monitor the effectiveness of this initiative during normal inspection activities.
19. Agreement was reached with the Dounreay Director that all future plant restarts at Dounreay will be supported by modern standards safety cases (MSSC's) and that a number of key cases will need to be implemented to give NII confidence to lift the Direction. At present only two MSSC's have been produced but these have not yet been fully implemented
20. A Licence Instrument has been issued Acknowledging receipt of the Preliminary Safety Report (PSR) and PSR Addendum for the D1209 Duct Containment Project, and setting a formal regulatory hold point prior to the active connection and commissioning phase. Construction and installation of the filtration building and equipment is well advanced and has proceeded at the licensee's own commercial risk.
21. UKAEA has identified operational difficulties associated with BPM for discharges required for transferring ADU liquor from the suspect leaking Tank 1 to Tank 3. This matter is being discussed with SEPA.
22. UKAEA submitted an application for an agreement to the active commissioning of the LMD plant. A project assessment report supporting the issue of a licence instrument agreeing to the commencement of active commissioning is complete. SEPA has indicated that there are problems associated with the analytical techniques for radiometric assessment of the bulk liquid effluent and their agreement to the issue of this licence instrument is still awaited.
23. A UKAEA investigation found that control and supervision was not a contributory causal factor concerning the scaffolder stepping outside the handrail on the DFR roof without a safety harness. The use of safety harnesses has been covered in a site safety brief and NII now considers the issue closed.
24. Following discussion with NII, UKAEA withdrew its request for an Acknowledgment of the Category B Modification for the DFR NaK disposal plant. The request was premature as all the reference support documents were not available.
25. NII has received a request for acknowledgment of the PSR for DFR sodium potassium characterisation (NaK) operations. NII's assessment includes scrutiny of UKAEA's proposal to progress visual examination of the NaK crust.
26. A site meeting was held on progress with improvements to the site Infrastructure management arrangements as required by R118 of the Dounreay audit. An LC36 management of change project has been initiated and the development of the modern standard safety case for essential site services has been brought forward at the request of NII.
27. A meeting was held in Edinburgh to consider licensed site boundary issues associated with future works for the shaft waste retrieval project. NII tabled notes explaining the procedure involved in an application for re-licensing the Dounreay site to effect a change to the site boundary. Such an application is not expected before August 2003.
28. A consultant has been appointed by UKAEA to determine how these regulations apply to decommissioning projects at Dounreay. It is estimated that the report will be available to the regulators at the end of May. A site wide Environmental Impact Assessment has been started and it was agreed that quarterly progress report would be sent to the regulators as the project will take over a year to complete.
29. A letter was received from UKAEA proposing that very low radioactive material (VLRM) should be mounded on the site rather than being placed as now in an undercover store pending disposal. A video conference was held and UKAEA agreed that all the options for interim storage and disposal should be considered in a safety overview paper.
30. In this period, the following matters in particular have been inspected and discussed:
31. An inspection of the site access induction training arrangements was carried out during the quarter. This inspection was carried out to time with the large number of visitors to the site in preparation for start up of Vulcan reactor operations. The arrangements appeared to be comprehensive and well organised. Training included visits and demonstrations with lectures on security, industrial safety, radiation safety, a quality and environmental module, authorisation procedures and nuclear facilities access arrangements. There was no formal fixed arrangement for refresher training but this is reviewed on a case by case basis depending on individual requirements.
32. Inspections were carried out to review safety arrangements during the reactor start up and testing programme. The inspection included discussions with the reactor operators and support staff, examination of operating procedures and reactor safety case. All the arrangements were found to be satisfactory.
33. Meetings were held during the quarter on Vulcan's arrangements for compliance with REPPIR requirements. Advice was given on required further development of documentation to meet statutory requirements.
34. An inspection was made of the arrangements for undertaking radiological surveys of working areas. The surveys included monitoring for radiation and contamination. The arrangements all appeared to be satisfactory.
35. A sample inspection of compliance with the Ionising Radiations Regulations 1999 was carried out during the quarter. The inspection included arrangements for accounting of radioactive substances, designation of working areas, keeping of radioactive sources and testing of radiation monitoring instruments. All the arrangements appeared to be generally satisfactory. Some advice was given on the storage of radioactive liquids.
36. A routine meeting was held with site safety representatives. Topics included:
37. An inspection of the maintenance arrangements at VULCAN was carried out during the quarter. Following the inspection it was concluded that although the maintenance procedures are comprehensive and well understood on site, there needs to be greater clarity on the link between the site safety case and translation into maintenance requirements. The site management are currently reviewing the development of maintenance schedules and procedures.
38. During a site inspection in March the site inspector identified unsafe working at height by two workers on a tower scaffold. This matter was brought to the attention of the senior management who took immediate remedial action and have implemented a programme of safety awareness and additional worker training.
39. No improvement notices were served during the period of this report.
40. No events have occurred during the quarter that met the Ministerial reporting criteria.
41. As reported previously, damage occurred some time ago to a large number of respirators on the site. UKAEA Police continue to investigate.
42. NII has assessed the report of a suspected overexposure of an employee working in the D2670 facility of the FCA. We accept the approved dosimetry service's revised estimate of committed dose from 28mSv to 4.7mSv. No further regulatory action is planned.
43. An unregistered radioactive source associated with the DFR Ion Exchange Plant was discovered during maintenance of manufacturers equipment. UKAEA is investigating the circumstances of the event alongside a recent similar finding on the PFR Sodium Disposal Plant. NII is monitoring the investigation and is looking to carry out an enhanced inspection on source control in the near future.
44. NII was notified of the failure of a zinc bromide window in D1206 and follow-up inspections were carried out. The inspections revealed a number of deficiencies in UKAEA's arrangements. A letter has been written to UKAEA requiring a response by early April.
45. During the period of the report, no Directions under conditions attached to the Site Licence were issued. The Inspectorate has powers under the licence to issue Consents, Approvals and Directions. In addition, the Inspectorate uses Licence Instruments to issue Specifications, Acknowledgements, and Agreements under either the conditions attached to the Licence, or arrangements made by UKAEA for complying with those conditions.
46. NII has issued licence instruments for the following:
Acknowledgment of receipt of the PSR and PSR Addendum for the D1209 Duct Containment Project, and setting a formal regulatory hold point prior to the active connection and commissioning phase.
Agreement to modifications to install shielding around the D1202 CIDAS control cubicle. The CIDAS system in D1202 is a BNFL Mk 10 system.
Agreeing to modifications to the fire fighting system in D9867. The modifications were necessary to allow the installation of a new stack discharge sampling system.
Published on the HSE web site 10 June 2002