Health and Safety
Executive / Commission
Nuclear
LLC reports
This 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 Harwell Local Liaison Committee (LLC) and covers activities associated with the regulation of safety at Harwell. These reports are distributed quarterly. Site Inspectors of HM Nuclear Installations Inspectorate normally attend LLC meetings and will be happy to respond to questions raised there by members of the LLC. Any other person wishing to inquire about matters covered by this report should contact the HSE, Nuclear Directorate Information Centre on 0151-951-4103.
The main focus during the quarter was facility safety cases in terms of the key safety related posts required to implement safety case requirements. This theme will continue for part of the next quarter and follows on from our intention, for all Southern Division sites, to be satisfied that the licensee is exercising appropriate control of activities on the site. Support was also given to other UKAEA Southern Division sites. Work had already been been scheduled at Windscale associated with a review of the control of radioactive sources. In addition as a result of an event at Winfrith a more detailed inspection and review of the event was carried out with the Winfrtih site inspector.
The Site Inspector visited Harwell on the following days:
| 17 April | - | Site Inspection and meeting on PSR | |||
| 29 April | - | Site inspection | |||
| 21 May | - | 23 May | Site inspection | ||
| 19 June | 21 June | Site Inspection and Level 3 meeting on PSR |
In addition to visits by the site inspector other NII staff carried out regulatory activities on the site during the quarter. These were associated with the Environmental Impact Assessment of decommissioning Regulations and meetings and review of work associated with the periodic safety review programme and engineering substantiation. In total NII staff spent 17 days at the Harwell site.
Regulatory work has also been undertaken corporately at Risley and use continues to be made of video conferencing facilities.
Licence compliance inspection has continued to examine commissioning of plant and modifications. At the site annual review meeting and the UKAEA operational review NII has emphases the need for the licensee to be in control of tenant operations and this remains a theme for inspection. Emphasis has also been placed on examination of facility safety cases and how they are implementation by persons who hold safety related posts.
There has been inspection associated with generic topics that are applicable at more than one site. These groups have been established as part of the normal interface structure with UKAEA. They provide information at a site level but also as part of the UKAEA/NII operational review meeting.
A licence instrument has been issued to allow Dragon fuel to be received at Harwell. Receipt of Dragon fuel at Harwell has been examined during the quarter. The commissioning process in place was consistent with other arrangements in B462 and good information was being obtained. The process was well documented and UKAEA were clearly exercising control. This inspection will inform decisions for future licence instruments to support continued operation and further moves may be examined.
There has been a significant amount of discussion between UKAEA and NII concerning standardisation of planning of the annual demonstration exercise. The objective is to establish a matrix of parts of the emergency plan to be tested along with the frequency of test and performance expectations. The matrix has been in use at each UKAEA site for planning purposes during the last 12 months. Agreement is nearing on a generic matrix that will take account of local site variations whilst ensuring that the key parts of the plan are tested at known and agreed frequencies. This is seen as particularly important at Harwell and Winfrith where the nature of the sites is changing.
During the quarter there has been regular dialogue with UKAEA concerning the Periodic safety review. In addition UKAEA had started work on Engineering Substantiation. This forms an important part of the programme of development of modern standards safety cases. The scope of the PSR was agreed in June /July 2000. This is an important milestone in the process leading to submission of the PSR in July 2003. UKAEA had identified that work on engineering substantiation had an impact on the PSR in terms of the scope of the submission and programmes of work arising from the exercise. As the next key milestone was approaching, a series of meetings were held to clarify understandings. The aim being to reach a position by July 2002 whereby both sides had clarity over the scope and the programme of additional work to address issues identified by the PSR and Engineering Substantiation process.
UKAEA have developed a new system for nuclear materials accounting. The system has been tested and commissioned. Whilst it is a corporate system implementation is site based. During site inspections at UKAEA sites we raised issues associated with the safety duty of the system that affected site implementation. A corporate meeting has been held and UKAEA are now considering the implementation approach. Once this has been clarified NII will be in a better position to plan its inspection of the system. To support our decision concerning the quality of the engineering substantiation programme NII may carry out an audit of the process in early 2003.
UKAEA have put forward proposals to restructure and form a Major Projects and Engineering Division (MPED). The re-organisation represents an LC 36 change and UKAEA have made a submission to NII. NII have indicated to UKAEA that we will wish to examine UKAEA's proposals in line with its arrangements for LC 36, management of organizational change. The change mainly affects operations at Dounreay but there is some impact at Harwell concerning the Waste Retrievals projects. NII has reviewed these changes and as they have a minor impact on safety, allowed them to proceed.
AEAT has developed an exit plan from B 220 as part of its sale of Nuclear Science. This plan is focused on tasks that need to be undertaken to exit the building safely, consequently an important part of this plan is the need for the work to be adequately controlled. Many of the detailed tasks will be controlled through existing systems in B220. NII want to be satisfied that there is an overarching process and modifications are adequately categorised and controlled. There will be further dialogue with UKAEA and consideration is being given to the most effective regulatory approach to this project.
Regular dialogue takes place with the local Environment Agency Inspector. As part of the most recent Memorandum of Understanding (MoU), between HSE and EA a more formal discussion has been held to exchange information about inspection priorities and plans. The objective being to avoid dual regulation and coordinate the need for any joint inspection. This cooperation will continue.
EA have also kept NII informed about progress on the revised Harwell discharge authorisation.
NII has completed its assessment of the UKAEA submission and is currently preparing its report. It is intended that a publicly available report will be produced and published in late October.
During the period of the report, no Directions under conditions attached to the Site Licence were issued.
The following consents were issued
Lease of Building 353 T1 and Building 404.14 Units 3&4 at Harwell to Scion Technical Services Ltd. Issued 24/06/2002
Lease of Part Building 424, Harwell to RWE NUKEM Ltd. Issued 10/07/2002
Published on the HSE web site 29 August 2002