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 - 17 October Site inspection and visit by Mr B.J. Furness NII Deputy Inspector21 - 25 October Site Inspection
13 - 15 November NII investigation of D2001 contamination incident
18 - 22 November NII investigation of D2001 contamination incident
25 - 29 November Site inspection and Annual review of safety
9 - 13 December Site Inspection
2.
29 October Meeting at Risley on Solid ILW enabling works30 October Meeting at Risley on PFR raffinate treatment 7 November Meeting at Risley on D1208 start up 4 December Meeting at Bootle on UKAEA Project Management
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 annual reviews of safety, emergency exercises, start up of D1208, formation of the new UKAEA Major Projects and Engineering Division, and investigation of D2001 and Puma Cell contamination incidents.
5. Inspection of the Dounreay site has continued as planned during the quarter.
6. UKAEA has confirmed completion of the implementation plans for MPED. Therefore NII is content that MPED has been formed in compliance with the requirements of the agreement issued under Licence Condition 36. UKAEA is addressing future resourcing commitments stipulated by NII and we are monitoring the implementation programme. A 'mini-baseline' resource review will be incorporated into the general UKAEA baseline revision in April 2003. UKAEA will report on the development of that part of the Project Management Manual concerned with project resource adequacy in October 2003. Resources is now a standing item on the agenda for future DSRP meetings
7. The annual emergency exercise review meeting was held in November. A UKAEA report on past years site and plant exercises was discussed and it was generally agreed that they had been of an acceptable standard. The main exercise was the Level 1 Delta 34 held in May followed by a successful re-run of the forward control point arrangements in September. Lessons learnt from both the plant and site exercises are being applied across the site.
8. A level 2 exercise will be held August 2003 and it was agreed that site inspectors should observe along with the NII emergency planning team. A table top transport emergency exercise was held in December 2002 that was observed by NII. This exercise was a precursor to a full exercise to be held at Dounreay in March 2003. Observations for improvement included communications, potential hospital contamination and prompt supply of information to emergency services.
9. A very successful annual review of safety was held covering the main events of the past year. There were good contributions from Divisions of UKAEA, from a safety representative and the manager of an alliance company. One of the main outcomes was that a data base would be set up at Dounreay to capture all regulatory issues including those raised by inspectors at post inspection debriefs. This will help to prevent problems in interaction with regulators that have been the subject of letters from NII as reported previously to the DLLC. A number of other actions arose for UKAEA and these will be followed up in the normal course of inspection. UKAEA reported that the Dounreay Health and Safety Week began on 7 October 2002 and included a keynote address from Bill Callaghan, Chairman of the HSC. Also during the last few months, across the Dounreay site, several stress management workshops have been convened to collate information for use in the forward action plan. An overall progress report on the stress project will be sent to NII in early 2003.
10. NII has continued discussion with UKAEA on approval of the management arrangements for modifying key decommissioning timescales under licence condition 35. Licence Instrument No. 89 was issued on 21 October 2002 specifying under licence condition 35(3) that UKAEA submit the DSRP management arrangements to NII for Approval. Once approved the arrangements cannot be changed without NII's re-approval. Progress on individual decommissioning projects has been monitored during normal site inspections. The DSRP annual review meeting due to be held in November 2002 to allow UKAEA to identify any changes to the decommissioning programme was put back by NII as UKAEA were unable to send the necessary papers to the regulators by the required date due to operational difficulties. However, a useful preliminary meeting was held and the progress meeting has been rearranged for February 2003. A report on DSRP progress and the twenty seven outstanding medium term audit recommendations from the 1998 HSE - SEPA safety audit will be provided for the next DLLC meeting.
11. Outstanding recommendations one and seven refer to the revision of safety and environmental management systems in line with modern practice and the re-issue of a comprehensive user friendly set of documentation. A programme for finalising this work was agreed with NII in early 2002. However, progress is significantly slower than expected and NII is arranging a number of meetings with various levels of UKAEA management to ensure that the programme receives the priority it deserves.
12. NII's assessment found an issue concerning the possible overstressing at the supports for highly active liquor (HAL) tanks 1-8. Therefore, the main priority is for UKAEA to develop a tank emptying strategy that optimises safety and security requirements. The next step is to complete activities necessary to apply for start up consents for D1208 and the Dounreay Cementation Plant where the material will be made passively safe and then stored.
13. Problems with the Caesium Removal Plant are still delaying the active commissioning tests. The ion exchange beds are being redesigned and therefore the programme for the application for consent to operate the SDP is being revised (originally planned for December 02). If the resumption of the planned commissioning using primary sodium is further delayed a fallback position may be requested of NII in which secondary sodium is used. If this happens a new Licence Instrument will be required.
14. All of the reference support documents have now been submitted to NII for the NaK disposal plant. Review of these documents has identified the need for UKAEA to complete the design substantiation and carry out further work to revise the Pre Commencement Safety Report (PCSR). UKAEA's best estimate target date for re-application for acknowledgement of the PCSR is now May 2003. The DFR sphere ventilation upgrade report has been sent to NII for assessment.
15. The latest programme for production of MSSC's shows significant delay in the production of a large number of safety cases. UKAEA has stated that this is due to the unforeseen degree of engineering substantiation required for the existing plants. However, UKAEA believes that they will be able to produce the safety cases within the originally agreed overall time scale. NII will continue to monitor the process.
16. Because of concerns over Dounreay's LLW management strategy, the original Consent for commencement of routine operations at WRACS was limited to 31 December 2002. The Consent was conditional upon UKAEA achieving key milestones in the implementation of the LLW strategy, including obtaining agreement - in - principle from BNFL to dispose of Dounreay LLW to Drigg. All of these conditions were cleared by UKAEA. Following the submission and assessment of a report reviewing the performance and safety of the facility since operations commenced in July 2001, a new Consent has been issued to allow WRACS to continue operation beyond 31 December 2002. In order to maintain focus on the implementation of UKAEA's LLW strategy, the Consent is conditional upon UKAEA meeting key milestone dates for the commencement of LLW disposal and for submission of the final LLW BPEO Study.
17. Contingency arrangements for the fire fighters strike were discussed at a meeting with the site management, fire brigade and safety representatives. Dounreay undertook the necessary risk assessments and sent the contingency plans to NII.
18. A video conference was held with UKAEA on the development of the safety case for contaminated ground following a workshop on low level waste organised by NII in September 2002. The draft safety case relied heavily on monitoring of contamination left in the ground for very long periods of time rather than on planned remediation. NII requested that the strategy be reviewed to ensure that the hazard was being reduced in line with current decommissioning practice.
19. Mr Furness visited Dounreay and discussed NII priorities for hazard reduction at D1208 by transferring HAL to the Dounreay cementation plant and the development of the DFR NaK removal plant with both project managers and senior management. This reinforced the discussions on the same subjects when the Chief Inspector visited the site in September.
20. NII carried out inspections during this quarter on the following dates:
1 - 3 October 20025 - 7 November 2002
Also, the NII attended the emergency exercise planning meeting on 10 October, at Inverness.
Inspection topics covered during the above visit included:
The Nuclear Accident Response Organisation, training of staff and facilities. The records inspected were comprehensive and complete, and the training plan well managed.
The arrangements for Area Monitoring. VULCAN is supported by UKAEA staff for this and the arrangements were satisfactory.
An inspection of the arrangements for controlling and authorising reactor operations was undertaken. 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 satisfactory.
A meeting was held with the SEPA site inspector for VULCAN, at Dingwall. This was worthwhile, and it is intended that a close contact will be maintained in the future.
21. As discussed in the last quarterly report, NII issued an Improvement Notice following into an incident at WRACS, during which the NDA 20 Alpha assay system source inadvertently became unshielded during investigative maintenance work. UKAEA were requested to complete a number of short term actions prior to the recommencement of operations in WRACS. Following the short term actions and the submission of a programme for the longer term actions, WRACS resumed normal operations.
22. No events have occurred during the quarter that met the Ministerial reporting criteria.
23. Contamination Incident in D2001. On the 12 November, NII were informed that during exit from the D2001 ILW processing plant, the installed hand and foot monitor detected contamination on a worker's shoes. Health Physics checks revealed that around 17 other workers also had contaminated shoes. About 70 people were present in the building at the time and all were withdrawn from the facility and checked for contamination. Two of the workers (one UKAEA employee and one contractor) were found to have contamination on their hands; the UKAEA employee also had slight contamination on his face. The personal contamination was successfully removed the following day by the Occupational Health Department. Checks of the discharge stack monitors concluded that there was no evidence of an external release. Preliminary investigations revealed that the source of contamination was from an earlier flasking operation. Extensive Health Physics survey and decontamination work was carried out and NII agreed a recovery plan to unload the waste can from the flask into the waste processing cell.
24. A report on NII's investigation into the incident at D2001 is currently being produced. The cause of the contamination has been concluded to be the transport of free zinc bromide liquid in a container and transport flask not designed to provide leak tight containment. The final report will raise a number of short and long term actions which will require to be addressed by UKAEA, and will recommend enforcement action in accordance with HSE's Enforcement Management Model.
25. Contamination in PUMA Cell. On 5th November, UKAEA notified NII of an incident at the PUMA cell involving plutonium contamination of one contractor while erecting a tented enclosure to cover a sealed pit to be decontaminated. The PUMA cell, with the exception of the pit, had been decontaminated and reclassified to 'contamination low' in September 2002. UKAEA confirmed that operations were stopped and an internal investigation was initiated. NII started its investigation with a meeting on site in November at which the draft UKAEA investigation report was discussed and a number of issues including risk assessments and involvement of the RPA were raised for clarification. The incident was further investigated during week commencing 9th December and an NII report is being prepared utilising the HSE's Enforcement Management Model. Initial indications are that the contractor did not receive a significant intake of radioactivity.
26. 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.
27. Agreements were issued under Licence Condition 36 for the formation of The Major Projects & Engineering Division (MPED) and the reoganisation of Dounreay Division contingent upon formation of MPED.
28. A Licence Instrument has been issued acknowledging the Preliminary Safety Report for DFR breeder fuel removal with an intention to examine the further stages of the project.
29. Licence Instrument No. 89 was issued on 21 October 2002 specifying under licence condition 35(3) that UKAEA submit the DSRP management arrangements to NII for Approval
Published on the HSE web site 12 March 2003