Health and Safety
Executive / Commission
Nuclear
LLC reports
On Site Inspections
Meetings with SEPA and Other
Organisations
Routine Matters
Non Routine Matters
Regulatory Activity
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:
7- 11 April2. Meetings were held with SEPA on operational matters during site inspections and routine discussions were held on a day-to-day basis to ensure active cooperation on regulatory matters.
3. The main thrust of NII activity during the period of this report has been inspection of compliance with Licence Conditions, team inspection of modifications, planning and observation of the level one emergency demonstration exercise and further investigation of a number of unusual events/incidents reported in the last quarter.
4. Inspection of the Dounreay site has continued as planned during the quarter.
5. The Dounreay annual level 1 emergency demonstration exercise was held on 21 May. The scenario was a criticality event with a release of radioactive material to the atmosphere and casualties with physical and radiation injuries. The exercise tested the site arrangements for criticality evacuations, treatment of highly irradiated casualties, development of a recovery process including entry to the incident area and evacuation of personnel offsite. NII judged the exercise to be overall an adequate demonstration of the UKAEA arrangements. However, significant improvements are required to the welfare facilities and ventilation in the criticality evacuation centres. NII has written to the site requesting an improvement plan for these matters and also for certain outstanding issues from the 2002 exercise.
6. A Licence Instrument has been issued Approving UKAEA's arrangements for managing changes to the DSRP. The arrangements cover the way in which UKAEA will interact with NII to ensure that any proposed changes to the key strategic decommissioning dates are adequately justified and agreed. The DSRP has formed the basis of the Life Cycle Baseline (LCBL) for the site that is an integral part of the planning process of the Liabilities Management Unit (LMU). NII and the LMU are working together to ensure that their interactions with the site are complimentary. To this end site inspectors are attending a training course on the LCBL and will be involved in the forthcoming LMU review of the LCBL and 5 year work plans.
7. The NII DLLC report on the medium term audit recommendations from the 1998 HSE - SEPA safety audit was issued in April 2003. Since the November 2001 HSE/SEPA audit close out report UKAEA has made good overall progress and has continued to show commitment to the work required to close out the medium term recommendations. A few examples of this are:
Good progress has also been made in the period of these reports with the start up of waste management plants necessary for the decommissioning activities described in the Dounreay Site Restoration Plan DSRP. For example, WRACS LLW plant, D2001 waste processing plant and ILW stores. Additionally, there has also been a significant management development with the formation of the Major Projects and Engineering Division (MPED). Further progress meetings have been held with UKAEA and the arrangements for closing out the recommendations have been agreed.
8. Following the implementation and adoption of a Modern Standard Safety Case (MSSC) and completion of a satisfactory pre start-up compliance inspection by NII, Consent to commence operation of the DCP has been granted to UKAEA. Commencement of cementation of raffinate in the DCP will begin once has UKAEA applied for, and been granted, Consent to start operation of the feeder plant D1208. It is expected that this will happen soon following resolution of a number of NII issues.
9. The Sodium Disposal Plant is nearing the end of the planned maintenance outage. The agreed active commissioning programme will be completed by an endurance run in which 150 te of reactor sodium will be processed. UKAEA will then apply to NII for a Consent for full operation. Removal of sodium (Na) and sodium-potassium (NaK) from components on the site will leave a large quantity of steel contaminated by tritium in the form of low-level waste. NII is discussing the management of this waste with the site.
10. UKAEA has recently concluded on the basis of technical, safety, environmental, socio-economic and financial considerations that the best option for management of the PFR raffinate is cementation as ILW using a proposed new cementation plant, DCP2. A meeting is planned involving DEFRA, DTI, NIREX, EA, SEPA and NII to discuss this change in reference strategy which for several years has been immobilisation by vitrification. Vitrification remains the contingent strategy until after the cementation trials are complete and the alternative strategy is accepted.
11. The last quarter report noted further slippage in DFR decommissioning. There is still significant slippage on most projects due mainly to technical problems with pond decommissioning, ventilation safety case issues raised by NII and previous lack of engineering substantiation resources for the NaK disposal plant. NII is monitoring the situation closely as further slippage could affect the declared DSRP milestones.
12. The Fuel Cycle Area (FCA) at Dounreay has been shutdown since mid 1998 following a Direction from NII to halt processing operations. Initially, Consent for each plant restart required a high degree of regulatory scrutiny for each element of the process. In January 2002, a strategy was agreed with UKAEA that future FCA plant restarts would be subject to the implementation and adoption of modern standard safety cases (MSSCs), in accordance with revised UKAEA corporate and site arrangements. A number of MSSCs have now been implemented and new corporate and Dounreay arrangements for the implementation process are in place. In view of this progress, NII and SEPA held a meeting with UKAEA senior management at which the requirements and programme for lifting the Direction were discussed and agreed. UKAEA's draft programme of requirements indicates the Direction being lifted at the end of 2003.
13. Following extensive discussions with NII and SEPA, UKAEA has developed a programme for the completion of the contaminated ground safety case and implementation plan. Other developments include the revision of existing excavation procedures and the introduction of a safety related managerial post for contaminated ground matters. The programme is due to be completed by this November and the regulators have requested that any future projects necessitating excavation of contaminated land are covered by these arrangements.
14. NII is investigating the quality of incident analysis across all UKAEA sites. Information on Unusual Occurrence (UNOR) reporting and investigation process at Dounreay shows that on the whole, the UNOR arrangements in place are adequate. Nevertheless, some improvements have been identified and these will be included in a letter to UKAEA.
15. Inspectors from the NII Dounreay team carried out a planned inspection of modifications across Dounreay site. The inspection at Dounreay was the final inspection of a series covering all UKAEA licenced sites. Overall, based on the evidence of the sample inspection, the site showed generally good control of modifications. Therefore NII consider the close out of recommendation No 96 arising from the audit carried out in 1998 at Dounreay is progressing well and we expect UKAEA to request close out of the recommendation soon. Some areas for improvement were found and a letter has been sent to the site with our findings.
16. NII carried out inspections during this quarter on the following dates:
8 - 10 April;Inspection topics covered during the above visits included:
In general the inspections indicated that the site are satisfactorily managing and controlling the activities, and no significant issues were identified.
17. WRACS Sealed Source Incident.
The last three 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. NII has agreed that the notice has been complied with.
18. Contamination Incident in D2001.
The last quarter report discussed the background to NII's investigation into the incident that raised 15 actions to be addressed by UKAEA, three of which were incorporated into an Improvement Notice. UKAEA has now demonstrated acceptable implementation of the Improvement Notice and has provided satisfactorily responses to the remaining actions. As a result, NII has agreed to a lifting of the D2001 operations embargo that has been in place since the incident.
19. No events have occurred during the quarter that met the Ministerial reporting criteria.
20. D2580 Fissile Material Store.
Following the contamination incident in D2580 in March 2003 in which low levels of alpha contamination were detected on the shoes of two individuals involved in the inspection work, an embargo was placed on any operations in D2580 until UKAEA's investigation into the incident was completed and any appropriate recommendations implemented. Following an inspection of the procedural improvements made following the incident, NII has agreed to a limited lifting of the operations embargo to allow inspection and assessment of all the uranium packages in D2580, with interim overpacking where necessary. It will also allow an overdue Euratom stock take to be completed.
21. NaK Fire Incident.
A small NaK fire occurred in DNO26 waste store on 15 February 2003. There were no injuries and no detectable release of activity from the plant. The NII investigation into the incident has been completed and a letter sent to Dounreay requiring improvements in records, quality assurance of waste packaging and inspection as well as the formulation of a strategy and programme for treatment and destruction of other NaK contaminated items.
22. Contamination in PUMA Cell
As reported in the last quarter, a contamination incident occurred on 1st November 2002 during the erection of a tent preceding the decontamination of a pit in the PUMA cell. The NII investigation has been completed and a letter sent to Dounreay. This requires Dounreay to make improvements in the initial categorisation of incidents and task based risk assessments as well as in the reporting of contamination incidents by staff
23. Incident in PFR
An incident occurred on 5th June 2003 in which water entered the ventilation ducting of PFR. It is thought that the source of the water was the overflow pipework serving two storage tanks supplying the intermediate fuel caves. Much of the water drained into the decontamination pit of PFR and in doing so has become lightly contaminated. Decommissioning work stopped temporarily on the day of the incident and UKAEA has set up a Local Investigation that is being monitored by NII.
24. Incident at PFR Sodium Disposal Plant
During a routine inspection by a Zurich insurance inspector on the SDP on Thursday 15th May, a flange on a vessel was loosened and resulted in a spray of liquid contacting two Alstec employees. The incident was not reported to UKAEA management until the afternoon of Friday 16th May and NII was informed on Monday 19th May. The area was monitored on the Friday afternoon and low levels of contamination were detected. Initial results from whole body monitoring of those sprayed showed nothing unusual. NII's initial investigation has uncovered that certain written procedures were not followed.
25. 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. During the period of this report, no Directions, Consents or Approvals under conditions attached to the Site Licence were issued. The following licence instruments were issued during the period of this report:
Agreement to the commencement of operation of the new D1208 ventilation plant.Approval of the arrangements for the management of the DSRP.
Published on the HSE web site 15 September 2003