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.
The Site Inspectors visited Dounreay on the following days:
24 January - Site Inspection27 February - Site inspection and DSRP Annual Review. The NII Superintendent Inspector responsible for UKAEA regulation attended the Review. Visit by NII Specialist Engineering Inspector
10 - 14 March - Site Inspection, visit by project management inspector and inspection of Vulcan NRTE
29 January - Meeting at Stirling on Dounreay shaft decommissioning options attended by SEPA, RWMAC and DPAG
13 February - Meeting at Edinburgh attended by SEPA on Dounreay shaft decommissioning progress
18 March 20 - Meeting at Risley on DFR breeder fuel removal
19 March 21 - Meeting at Risley on DFR NaK Plant
Meetings were held with SEPA on operational matters during site inspections and offsite joint visits. A useful meeting took place between NII, SEPA, Scottish Executive, Highland Council, the government's advisory waste management body (RWMAC) and UKAEA to discuss the benefits of wider participation in DSRP related projects, and the development of UKAEA's process for public participation at Dounreay including candidate projects and associated risks to the DSRP programme. This was followed next day by a regulatory meeting to discuss Dounreay Shaft Isolation. The meeting was attended by representatives from SEPA, Dounreay particles group (DPAG), RWMAC and UKAEA.
The main thrust of NII activity during the period of this report has been inspection of compliance with Licence Conditions, annual review of the DSRP, review of outstanding medium term audit recommendations, shaft decommissioning, formation of the new UKAEA Major Projects and Engineering Division, and investigation of a number of abnormal events/incidents.
Inspection of the Dounreay site has continued as planned during the quarter.
UKAEA confirmed in January 2003 that the Major Projects and Engineering Division (MPED) had been formed. MPED has been set up to support UKAEA's drive to be the 'supplier of choice' to the Nuclear Decommissioning Authority (NDA) when it is formed in 2005. The MPED Licence Condition 36 resource Baseline Document is complete and will be forwarded to NII in April 2003. The Baseline Document should confirm that MPED is generally up to strength. UKAEA has confirmed that MPED is the intelligent customer for the UKAEA design authority to ensure that contractors work to the required standard.
The annual level 1 emergency exercise will be held in May 2003. NII will be observing the exercise and has agreed the exercise scenario and arrangements with UKAEA.
In the report for the previous quarter it was stated that an overall progress report on the Dounreay stress risk assessment project would be sent to NII in early 2003. UKAEA has now confirmed that the processing of the information provided by employees is taking longer than expected. NII has requested that priority is given to completing this work and producing the agreed report. Progress with other actions from the review is being discussed with the site.
The rearranged first DSRP annual review meeting was held in February. The format and wording of the UKAEA arrangements for management of the DSRP under Licence Condition 35 has now been agreed and a submission asking for NII's Approval is expected soon. Once approved the arrangements cannot be changed without NII's re-approval. At the meeting NII requested that some documentation provided by UKAEA to justify changes to the DSRP be resubmitted to give a better picture of its current status, and to provide a more adequate baseline for the future. This information is expected shortly.
The NII DLLC report for the last quarter promised that a report on progress of the twenty seven outstanding medium term audit recommendations from the 1998 HSE - SEPA safety audit would be provided for the April 2003 DLLC meeting. However, the UKAEA progress report on the recommendations lacked sufficient detail and NII required it to be resubmitted. The revised report has very recently been received by NII but due to the delays only an interim report will be given at the meeting. A finalised report will be produced shortly and issued to the DLLC.
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. This is needed to enable UKAEA to show transparency for compliance with the 36 standard licence conditions. A programme for completing this work had been agreed with NII but we have been concerned for some time that UKAEA had not been giving the necessary degree of commitment to the programme. Following a recent meeting between NII and UKAEA senior management, a letter was sent by NII to UKAEA to confirm that at the meeting UKAEA had agreed to give the matter a high priority. There is now evidence that the process for production of the associated procedures is going more smoothly. An improved procedure on safety case documentation (recommendations 96,97,98) is in place and should help to eradicate some of the difficulties experienced with inconsistency in modification procedures.
NII's assessment of the safety case to allow a phased restart of the facility, initially to transfer material test reactor liquor to the Dounreay Cementation Plant, is nearing completion. There remain a number of issues related to the start up of D1208 and DCP and to be closed out to NII's satisfaction but it is hoped that UKAEA will be able to apply to NII in the near future to begin operations.
The Caesium Removal Plant active commissioning test will start soon as problems with the ion exchange beds have been resolved. Development of the water vapour nitrogen (WVN) process for removing sodium residues is progressing well. However, NII will be carefully monitoring the safety aspects of the process as it moves towards full-scale working. UKAEA is giving consideration to the uncertainties associated with the application of the WVN process to removing residues from the IFC caves. It is thought that the WVN process may not be suitable and alternative methods are being considered by UKAEA.
The last quarter report said that UKAEA's new best estimate target date for re-application for acknowledgement of the Pre Commencement Safety Report (PCSR) for the NaK disposal plant was May 2003. This has now slipped further to October 2003 mainly due to NII's assessment of the project that has indicated that there needs to be improvements made to the safety systems. NII is in the process of assessing UKAEA's response to issues raised by Specialist Inspectors and has identified the need for further assessment of matters such as fire safety. The DFR sphere ventilation upgrade report has been sent to NII for assessment and is receiving high priority. However, there are still some issues remaining about the interaction of this project and the new fire safety case that is under development. This matter could delay the agreement to commence construction of the ventilation plant.
UKAEA has reported that all of the MSSC's for the waste management group of facilities are expected to be completed by the end of this year. New procedures for implementation of the cases have also been produced by UKAEA. This is a major step forward and NII is now considering moving towards lifting the FCA Direction completely once a representative number of the MSSC's have been implemented.
The UKAEA request for transfer of operational LLW to Drigg has been processed by SEPA and sent to statutory consultees for consideration. The next step will be public consultation, probably by the middle of the year.
UKAEA has developed and is discussing with NII a programme for remediation of the existing barriered contaminated ground areas on the site. The timing and other details of this programme will be discussed at a joint meeting between NII, SEPA and UKAEA this April. UKAEA needs to develop an adequate strategy for dealing with all contaminated ground so that DSRP target dates for building facilities for the shaft and silo decommissioning can be met. This will also be a topic for discussion at the meeting.
The UKAEA site inspection unit is represented on the LMU Regulatory Interface Forum by the lead Dounreay site inspector. The forum, which includes representatives of all regulators and the Scottish office, meets regularly to progress regulatory interface matters for the formation of the Nuclear Decommission Authority. The site inspector will be attending the LMU stakeholder meeting in Thurso on 19 May 2003.
NII carried out inspections during this quarter on the following dates:
11 - 13 March 2003.Inspection topics covered during the above visit included:
The last two quarterly reports discussed the Improvement Notice issued by NII following an incident at WRACS, during which the NDA 20 Alpha assay system source inadvertently became unshielded during investigative maintenance work. UKAEA has now written to NII within the allotted time giving responses to the Improvement notice requirements and associated letter. NII is currently assessing the responses.
On 12 November 2002 NII was informed of an incident in D2001 ILW Processing Facility at Dounreay. Some contamination had been discovered on workers shoes, and two people were sent to the Occupational Health Department for decontamination. Whilst the actual doses received were later confirmed to be very low, NII considered this to be a potentially serious event and initiated an investigation to establish the root cause and to determine if regulatory action was required. UKAEA also initiated its own internal investigation. NII's investigation commenced on the 13th November 2002 and later concluded that the source of the contamination was from a small quantity of contaminated Zinc Bromide liquid, which had leaked from an internal transport flask. The flask and associated waste container and bagging system were not designed to provide containment of free liquids and hence the Zinc Bromide found a leak path to the working area. As a result of this investigation, and in line with HSE's enforcement policy, an Improvement Notice was served on UKAEA under the Ionising Radiations Regulations 1999, requiring improvements to be made to the flasking design and operations.
No events have occurred during the quarter that met the Ministerial reporting criteria. However, there appears to be an increase in the rate of occurrence of radiological events on the site, which are of concern to NII, and we are discussing them with UKAEA. Fortunately, although there was potential for personal harm, none of the incidents resulted in significant intakes of radioactive material. The incidents have a common theme of the absence of a suitable and sufficient risk assessment. Therefore, NII will be targeting risk assessment matters through enhanced inspections in the 2003 - 2004 inspection plan.
Following the routine inspection of packages in D2580 Fissile Material Store, low levels of alpha contamination were detected on the shoes of two individuals involved in the inspection work. A controlled re-entry revealed one of the packages had failed and local contamination was detected on the floor. Nose blow samples for detection of intake of radioactive material indicated nothing measurable. NII is carrying out an investigation into the incident and has asked for an embargo on further movements of packages until its' own and UKAEA's investigation recommendations have been adequately implemented.
A small NaK fire occurred in DNO26 waste store on 15 February. This is currently under investigation by NII and SEPA. The main issues which have been uncovered so far are: an inadequate strategy and programme for the management of NaK contaminated items at both PFR and DFR, the need for better monitoring of the drums in the store, inadequate quality assurance for packaging and storage of drums and better records required for drum contents. NII has asked for an embargo on further NaK wetted wastes being produced until the investigation has been completed. Further information is being obtained from site visits with a view to establishing appropriate enforcement action.
As reported in the last quarter, on 5 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. It has been confirmed that the person did not receive a significant intake of radioactivity. NII investigated and was disappointed with the quality of the UKAEA investigation process and draft report. NII's detailed concerns were transmitted to UKAEA. Improvements were made to UKAEA's final report that has just been received by NII.
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. No Licence Instruments were issued during the period covered by this report.
Published on the HSE web site 6 June 2003