Health and Safety
Executive / Commission
ND: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.
The Site Inspectors visited Dounreay on the following days:
15 - 19 April - Team Inspection of Maintenance and Site Inspection
20 - 24 May - Annual Emergency Exercise, Site Restoration Progress
Site Inspection, DLLC meeting
24 -28 June - Site Inspection
No off site meetings were held with UKAEA during the period of this report.
Video conferences took place with UKAEA regarding:
Meetings were held with SEPA on operational matters during site inspections. NII management and site inspectors met with their SEPA counterparts to discuss matters of mutual interest and arrangements for complying with the new HSE-SEPA memorandum of understanding. The respective inspection team leaders also met toagree joint site inspection arrangements.
The main thrust of NII activity during the period of this report has been the team inspection of maintenance, DSRP and audit management arrangements, annual site emergency exercise, assessment of revision of DSRP volume 6 (fuels), progress of major decommissioning projects, transfer of LLW to Drigg and the new UKAEA Major Projects and Engineering Division.
Inspection of the Dounreay site has continued as planned during the quarter.
NII has examined the Management of Change documentation submitted in support of the formation of a UKAEA Major Projects Division. We are generally supportive of this initiative, and initially consider that the structure of the Division is adequate in principle. However, we have requested that the change should not proceed until we have considered the submission in support of the consequential changes to the Dounreay site organisation.
The annual Level 1 emergency exercise was held on 22 May and was based on a release of radioactive material following a fire in a plant in the FCA. NII found the exercise to be overall an adequate demonstration of the appropriate parts of the Dounreay Emergency Arrangements. We were particularly encouraged by the effective evacuation of personnel from the FCA and relocation of the FCA emergency control centre during the exercise. However, the arrangements at the Forward Control Point need to be improved. We previously outlined our concerns on this issue after Delta 33 in May 2001. UKAEA has agreed to rerun this element of the exercise later this year after improvements are in place.
UKAEA has completed a risk assessment for offsite car parking and NII has asked UKAEA to ensure that the assessment covers the effects, if any, on emergency evacuation arrangements.
A team inspection of Dounreay's arrangements under licence condition 28, examination, inspection, maintenance and testing, was carried out. Included within the scope was an inspection of the arrangements developed and implemented by Dounreay in response to the maintenance recommendations of the Dounreay Audit. The team was composed of Dounreay inspectors and inspectors from other NII Divisions to enable an element of 'benchmarking' to take place. In addition, maintenance of environmental equipment was covered by a team member from SEPA.
Overall it was concluded that significant progress and improvements to the site's maintenance arrangements have been made since the Dounreay Audit. However, further developments and improvements are required, some of which UKAEA has already recognised. In order to ensure successful and timely implementation of these further improvements, a fully considered implementation programme is required. This programme will then be used by both UKAEA and NII to monitor progress.
UKAEA has now implemented a programme of risk assessments for Dounreay Division employees as required by NII at the annual review of safety in November 2001. NII has requested that the UKAEA Corporate staff working at Dounreay are also included in the programme. We have also encouraged UKAEA to involve safety representatives as far as possible in carrying out the assessments. UKAEA has agreed to provide a report on the study for the next annual review in November.
The first annual meeting to discuss UKAEA's progress in achieving the milestone timescales associated with the remediation of the Dounreay site was held on 23 May 2002. UKAEA was informed of NII's intention to approve the arrangements that have been developed for the management of the DSRP, under licence condition 35. This means that the arrangementscannot be changed without NII's approval. Progress on Individual decommissioning projects will be monitored during normal site inspections and a meeting will be held in November of each year to review progress and agree any justified changes to the arrangements or plan.
NII specialist and site inspectors visited the site to discuss volume 6 of the DSRP on fuels that has been updated following the Minister's decision to end reprocessing at Dounreay. We are content that our comments on the document at the draft stage had been incorporated. UKAEA is in the process of completing a risk assessment on the fuels proposals that will include the timing and financial aspects. NII will continue to monitor progress.
The second in a series of joint meetings with SEPA and UKAEA on proposals for restarting D1203 to recover unirradiated enriched uranium was attended. UKAEA had produced a draft optioneering paper for treatment of the material as requested by NII and it was discussed in some detail. The paper will be updated to take the regulator's comments into consideration.
NII and SEPA have continued to discuss with UKAEA progress on audit recommendation 80 related to UKAEA's review of options for the storage and disposal of LLW. UKAEA has been given permission in principle by BNFL to send LLW to Drigg and has applied to SEPA for a transfer authorisation. SEPA are progressing the application and will then carry out the necessary statutory and public consultation. Further discussions were held with UKAEA and SEPA on the BPEO for long term disposal of LLW. A draft programme to complete the BPEO exercise has been sent to the regulators for comment. Discussions have also been held with UKAEA on the requirements necessary to secure continued operation of the LLW WRACS facility beyond December 2002.
Following concerns about compliance with these licence conditions as reported in the last quarter, NII has been monitoring the effectiveness of an initiative to improve Dounreay's compliance with their arrangements for these licence conditions. UKAEA has given seminars to a large number of employees to explain both nuclear safety and environmental compliance requirements. Despite this there has been a recent reoccurrence of non compliance and NII has requested senior management to implement immediate remedial action.
Inactive commissioning of the new D1208 ventilation cleanup plant has been completed, and UKAEA has applied for agreement to commence active commissioning. Several issues have been raised with UKAEA on the Inactive Commissioning Report, for which a response is awaited.
UKAEA is carrying out a further options study on the transfer of ADU liquor from the suspect leaking Tanks 1 and 2 to the new Tank 3, and on dealing with the supernate liquor in the tanks. UKAEA has now accepted SEPA's position that any discharge of supernate will have to undergo some degree of abatement. The preferred option will require a robust BPM case therefore timescales are likely to be of the order of several months.
NII has now confirmed that SEPA has no objections to the commencement of this activity and a licence instrument is being prepared.
Some of the reference support documents have not yet been submitted. UKAEA's best estimate target date for reapplication for acknowledgement of the Pre Commencement Safety report is August 2002.
As reported in the last quarter, 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. NII continues to monitor the development of the appropriate safety cases.
NII carried out inspections during this quarter on the following dates:
20 - 23 May 2002
During the above inspection period the NII witnessed a Dounreay emergency exercise. The Vulcan site inspector witnessed the emergency response at the Dounreay Emergency Centre (DECC) since this facility is also used to support an emergency at the VULCAN site. When in that mode, VULCAN senior staff man the key posts, with other positions filled by UKAEA staff. NII confirmed from the exercise that the interface arrangements between the two organisations worked well and it was concluded that the exercise was considered to be a satisfactory demonstration of the emergency arrangements at Dounreay, which support the VULCAN site.
Although only one site visit was made to Vulcan during the quarter, the NII have been engaged in progressing outstanding site related matters including the implementation of requirements under Radiation (Emergency Preparedness and Public Information) Regulations 2001 (REPPIR). Work in all these areas is considered to be progressing satisfactorily.
No improvement notices were served during the period of this report.
No events have occurred during the quarter that met the Ministerial reporting criteria.
As reported previously, damage occurred some time ago to a large number of respirators on the site. UKAEA Police continue to investigate.
On 31 May 2002 UKAEA reported a small fire in the D1207 facility of Dounreay. D1207 is used as a temporary storage area for drummed low level waste, prior to transfer to the WRACS (Waste Receipt Accountancy Characterisation and Supercompaction) facility. Separate investigations were carried out by UKAEA Constabulary and UKAEA Dounreay Management. The UKAEA Constabulary has also informed the Procurator Fiscal that NII is undertaking its own investigations into this incident .
The previous report referred to the discovery of unregistered sealed radioactive sources in proprietary equipment installed in PFR and DFR. It also stated that NII were monitoring the NII investigation and would carry out an inspection on source control. NII is content that UKAEA's investigation resulted in recommendations that are likely to prevent a reoccurrence of the incidents. NII's inspection of source control covered Dounreay's arrangements for compliance with the Ionising Radiations Regulations 1999, in particular for the storage and leak testing of sealed sources. The control arrangements were found to be good apart from at one store where the day- -to-day records for the transfer, movement and return of sources were unsatisfactory. UKAEA has been required to improve the recording arrangements.
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 and a reply has been received.
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.
NII has issued licence instruments for the following:
An acknowledgment and notification of intent to examine the category A modification for the intrusive examination of the DFR NaK crust
NII has issued new fire certificates for the Dounreay site following a very significant improvement programme resulting from HSE inspections.
Published on the HSE web site 9 September 2002