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:
| 22-25 July | Site inspection | |
| 2-6 August | Site inspection | |
| 2-5 Sept. | Site Inspection | |
| 2-3 Sept. | Visit to the site by Mr L Williams Chief Inspector of Nuclear Installations and Dr A Ellis Head of HSE Field Operations Division to inspect DFR, PFR, FCA and to discuss key decommissioning matters with Dounreay senior management. Workforce safety representatives were also met. | |
| 9-12 Sept. | Site inspection |
| 18 July | Audit recommendation progress - Warrington | |
| 1 August | Management system developments - Risley | |
| 7- 8 August | ILW New plants progress - Edinburgh | |
| 9 August | Major projects and engineering Division - Edinburgh | |
| 24 Sept. | Management system developments - Risley | |
| 30 Sept. | Very low level waste and ground contamination - Edinburgh |
3. Meetings were held with SEPA on operational matters during site inspections. NII site inspectors met with their SEPA counterparts on 1 October to discuss regulatory matters of mutual interest.
4. The main thrust of NII activity during the period of this report has been the DSRP and audit management arrangements, repeat of part of the site emergency exercise, assessment of revision of DSRP volume 6 (fuels), progress of major decommissioning projects, transfer of LLW to Drigg, start up of D1208, formation of the new UKAEA Major Projects and Engineering Division and investigation of a source exposure incident at WRACS.
5. Inspection of the Dounreay site has continued as planned during the quarter.
6. NII has completed its examination of the Management of Change documentation submitted in support of the formation of a UKAEA Major Projects Division. A licence instrument agreeing to the change has now been issued by NII. There are a number of conditions attached to the agreement including that the implementation plan will be completed within the proposed timescale.
7. The annual Level 1 emergency exercise was held on 22 May and NII found the exercise to be, overall, an adequate demonstration of the appropriate parts of the Dounreay emergency arrangements. However, the arrangements at the Forward Control Point needed to be improved. A re-run of this element of the exercise was held and NII observed a very significant improvement. UKAEA has agreed to formalise these arrangements and implement them across the site.
8. UKAEA implementation of a programme of stress risk assessments has been monitored by NII and UKAEA has agreed to provide a progress report for the next NII - UKAEA annual review of safety in November.
9. NII has been discussing with UKAEA approval of the management arrangements for modifying key decommissioning timescales (under licence condition 35). Once approved the arrangements cannot be changed without NII's re-approval. Progress on individual decommissioning projects has been monitored during normal site inspections and an annual review meeting will be held in November to allow UKAEA to identify any changes to the decommissioning programme. The arrangements will require any changes to be fully justified to NII. A progress report on DSRP progress and audit recommendations will be provided for the Next DLLC meeting.
10. NII specialist and site inspectors comments have been included in volume 6 of the DSRP on fuels that has been updated following the Minister's decision to end reprocessing at Dounreay. UKAEA is in the process of completing a risk assessment on the fuels proposals that will include the timing and financial aspects. NII continues to monitor progress.
11. NII has provided UKAEA with comments on a draft optioneering paper for proposals for restarting D1203 to recover unirradiated enriched uranium. A progress meeting has been arranged for November and discussions are also being held by videoconference.
12. SEPA are progressing the application for transfer of LLW to Drigg and will then carry out the necessary statutory and public consultation and it is hoped that transfer could begin in Spring of next year if the consultation goes to plan. UKAEA are continuing work on the BPEO for long term disposal of LLW. Discussions are also being held with UKAEA on the requirements necessary to secure continued operation of the LLW WRACS facility beyond December 2002.
13. Inactive commissioning of the new D1208 ventilation cleanup plant has been completed, and NII has issued an agreement to commence active commissioning.
14. UKAEA is now working on abatement of the necessary discharge of supernate in order to empty the suspected leaking tank. SEPA is the lead regulator for this part of the process.
15. Following the issue of Licence Instrument No. 81 agreeing to the commencement of the active commissioning phase for the sodium disposal plant, approximately 17Te of liquid metal has been processed, this quantity is made up of 1.7Te primary sodium from the reactor vessel and the balance from the secondary sodium circuits.
16. All of the reference support documents have now been submitted to NII. UKAEA's best estimate target date for re-application for acknowledgement of the Pre Commencement Safety report is later this year. NII is discussing with UKAEA the comparison of the engineering of the plant with modern standards.
17. An update of the MSSC programme will be given to NII in November at the annual review of safety meeting. However there are indications that the programme has slipped since the last review in May. The NII safety assessment of the D1208 safety case has led to a review of the tank emptying policy and UKAEA are actively looking at the options for passivation of the liquid by either vitrification or cementation.
18. 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 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.
19. NII carried out inspections during this quarter on the following dates:
10 - 12 July 2002.Inspection topics covered during the above visit included:
Discussion with senior management on action taken to improve control of scaffolding work on the site.
Discussions were held on the next emergency exercise at VULCAN planned for November 2002. The exercise had been specifically designed to test the strategic response to an emergency. The opportunity will also be taken to examine the communications between the Vulcan Emergency Control Centre, the Dounreay Emergency Control Centre and the Local Authority/Police HQ. [The exercise has now been deferred to a later date as a result of the firefighters dispute]
An inspection of site radiography and enclosure radiography was carried out. All the arrangements appeared to be satisfactory.
The arrangements for how operations are authorised on the reactor systems were inspected. The arrangements and procedures are strictly controlled by a Procedure Authorisation Group and also require to be submitted to various MoD agencies, prior to executive authority being given. The arrangements appeared to be generally satisfactory.
A meeting was held on succession planning for RN and Rolls Royce staff. The arrangements for both groups appear to be sound and robust.
20. During investigative maintenance work on the teleflex cable of the NDA20 Alpha assay system at WRACS, the LLW processing facility, the Californium 252 source inadvertently became unshielded. The three people working on the system, together with other staff working in the WRACS facility, immediately evacuated the building. A recovery plan was formulated and executed. NII and UKAEA carried out investigations to establish the cause of the incident. Our investigation also looked at a previous incident in the plant to see if there were any common causes. The findings of our investigation were analysed by the HSE Enforcement Management Model (EMM) which recommended an improvement notice to be served. The notice stated 5 contraventions of the IRRs 1999 i.e. Reg. 7(1) no suitable and sufficient risk assessment, Reg. 8(1) exposure not reduced as far as reasonably practicable, Reg. 8(2) deficiencies in engineering controls and design, Reg. 8(4) improper use formal system of work, Reg. 13(1) no advice sought from a Radiation Protection Adviser. A letter was sent to UKAEA detailing the actions that need to be completed prior to WRACS being restarted and some longer term improvements.
21. No events have occurred during the quarter that met the Ministerial reporting criteria.
22. As reported previously, damage occurred some time ago to a large number of respirators on the site. It is now believed that the damage is likely to be due to mechanical handling during the laundering process. NII is content that there are sufficient respirators on the site for normal operations and emergencies and will therefore be no longer reporting on this issue.
23. In was reported in the last quarter that 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. Separate investigations were carried out by UKAEA Constabulary and UKAEA Dounreay Management. It is now believed that this was a one off incident involving misuses of the area by persons unknown. NII carried out a series of unannounced inspections in a number of areas on site and found no further evidence of such misuse. Therefore no further action is being taken.
24. 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 areas where a number of UKAEA's arrangements could be improved. NII is presently monitoring UKAEA's response to our concerns.
25. 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.
26. NII has issued licence instruments for the following:
Agreement for the active commissioning of the D1208 ventilation improvements and setting a hold point prior to operation.
Transfer of KFK fuel from a pond to a waste facility.
Agreement for MPED formation and reorganisation of Dounreay contingent upon formation of MPED.
28. An Improvement Notice was issued for a source exposure incident in the WRACS plant.
Published on the HSE web site 20 January 2003