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 has again been facility safety cases. A theme of examination of control of modifications has been followed in the Harwell operations department. Other safety case issues have been examined as part of follow up to an event and an initial examination of UKAEA's programme of engineering substantiation.
Support was also given to other UKAEA Southern Division sites. This has included attendance at the Windscale emergency exercise, completion of the control of radioactive source inspection reported last month plus planned corporate meetings.
The Site Inspector visited Harwell on the following days:
| 3 July | - | Site Inspection and level 3 meeting on PSR | |||
| 16 July | - | 19 July | Site inspection | ||
| 7 Aug | - | 9 Aug | Site inspection | ||
| 21 Aug | 22 Aug | Site Inspection | |||
| 3 Sept | 5 Sept | Site inspection |
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 examination of UKAEA's crane review, retrieval machine operations, PSR and lease consents. 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 focused on two main areas.
An inspection of UKAEA's arrangements for control of modifications has commenced. The first phase has focused on B 220 plus the site wide arrangements for control of modifications. The procedures in B 220 have evolved over the last two years with a more process driven approach now in place. The inspection identified that improvements have been made. Action tracking has improved and more positive control exercised by UKAEA. A site wide database has also been set up that facilitates tracking across the site. This system is more in line with NII's expectations of a site modifications register.
Following on from last quarter's theme of control by principal post holders, discussions have been held about overall manning levels in relation to the nature of the site and future changes. This links to UKAEA's LC 36 baseline assessment. It is clear that UKAEA are actively keeping this under review and looking closely at the competencies required for operations on the site for their own staff and any key support contractors. The later is an indication of increased scrutiny by UKAEA of performance by contractors.
Dragon fuel moves continued during the quarter and commissioning has been completed. UKAEA have submitted a commissioning report to NII in respect of the Harwell work and a licence instrument for full operations has been requested. A similar licence instrument has been received in respect of Winfrith. This was received at the end of August. There are some outstanding issues that are still under discussion and hence the licence instrument has not been progressed in line with the UKAEA project programme of mid October.
Work has continued at a corporate level to agree a standard for emergency arrangements. This is aimed at agreeing elements to be tested as part of a demonstration exercise as well as the performance criteria.
PSR progress was formally reviewed with UKAEA in early July (decision date minus 2 years milestone). The objective was for NII to understand the current position and the emerging issues. NII is still content with the overall process proposed by UKAEA. Resources on both sides have to be targeted in an appropriate manner and the engineering substantiation proposals are considered to be fit for purpose. NII will examine the possibility of sampling this work before the PSR submission date of June 2003. A further key feature is UKAEA's process for prioritising issues arising from engineering substantiation and the PSR process. This will form the basis of an implementation programme. NII is content with the process proposed and recognises that not all improvements can be implemented by the decision date. This is a further area where NII is likely to target resource for inspection.
UKAEA have now come forward with proposals to change over to the revised arrangements for Nuclear materials accounting in respect of Harwell and Winfrith. This forms part of an overall corporate programme that will require a licence instrument during the next quarter. NII is content with the principles and method of operation at Harwell.
Nuclear Science sale, by AEAT, is a project that has an impact at Windscale and Harwell plus other parts of the nuclear industry. It is being handled as a single project by NII. The overall programme dates for this project have gone back but it does not however impact on the overall exit plan for B220. A framework for regulatory involvement consistent with NII's inspection plan for Harwell is still in progress and a review conducted during the quarter. A further inspection is planned for the end of the year to review the arrangements for control of removal of key safety related equipment.
Regular dialogue takes place with the local Environment Agency Inspector. During this quarter the dialogue has concerned specific site projects rather than overall programmes. Good dialogue is being maintained.
NII has completed its assessment of the UKAEA submission. The report is currently undergoing some further internal review and clarification of points with UKAEA before final publication.
NII were notified of an event on the Pelloby crane in B 462. This crane is a key link in the retrievals programme. The event led to a more detailed examination by UKAEA of some of the claims made in the safety case. In this instance, concerning the flask used to retrieve the waste. UKAEA brought forward the engineering substantiation work programme and carried out a more detailed analysis. This has now led to improvements being proposed. NII is please that effort was diverted to this work. It has also provided an insight into the engineering substantiation programme in practice, providing some confidence in the UKAEA process proposed for the PSR. Some programme delays have occurred but we believe that this is a good example of UKAEA using internal hold points and a structured review process.
As part of this work one of NII's specialists has been involved and this has included examination of UKAEA's wider review of crane safety. This is a UKAEA wide project.
NII view the NSC as a key safety committee in any organisation Licence Condition 3). NII and UKAEA have been in discussion or some time concerning the terms of reference of this committee and membership. The arrangements for "fast track procedures" have been received and considered to be appropriate. UKAEA has also put forward revised proposals for the operation of UKAEA's two NSC's (Dounreay Division and Southern Division). These now proposals include and enhanced peer review process and phasing out the site based safety working parties. The principles have been agreed with UKAEA and following completion of NII's internal arrangements for preparation of project reports a licence instrument will be issued.
During the period of the report, no Directions under conditions attached to the Site Licence were issued.
The following consents were issued;
Lease of part of Building 404 at Harwell International Business Centre to ISS Servisystem Ltd. Issued 8/08/2002
Published on the HSE web site 27 January 2003