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.
Justin McCracken HSE Deputy Director General visited the site accompanied by Mr Furness NII Deputy Chief Inspector, Mr Robinson NII Superintending Inspector and members of the NII site inspection team. Visits were made to PFR, the Wet Silo, D1203 and DCP.
2. Meetings were held with SEPA on operational matters during site inspections and an inspection team meeting was held in the SEPA Perth office on 9 July.
3. The main thrust of NII activity during the period of this report has been inspection of compliance with Licence Conditions, further monitoring of UKAEA investigations of a number of incidents reported in the last quarter DLLC report and the issue of a number of licence instruments for UKAEA operations and projects.
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 and NII wrote to UKAEA with their observations and recommendations that have now been included in the UKAEA final report. A review of progress in closing out the recommendations from this exercise and plant exercises held during the year will take place at a meeting with UKAEA in November.
6. 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 complementary. The annual NII review meeting for the DSRP with UKAEA will take place in November. UKAEA are in the process of producing the agreed documentation for NII well in advance of the meeting so that NII can assess any proposed changes. Agreement to the changes will only be given if they are fully justified.
7. NII has also held discussions with UKAEA on the arrangements for the proposed PFI for the new conditioned waste store. UKAEA has agreed that they will own the store and therefore a possible major stumbling block to NII agreeing to the proposal has been overcome.
8. The annual NII report to the DLLC on the medium term audit recommendations from the 1998 HSE - SEPA safety audit was issued in April 2003. Since then NII has been monitoring progress and UKAEA believes that it will be in a position to request close out of about 12 recommendations by the end of the year. The programme for lifting the Direction on FCA operations is progressing well and it is expected that NII Consent is likely to be granted early next year.
9. Following the implementation and adoption of modern standard safety cases and completion of pre startup compliance inspections, Consents have been granted to re-commence operations at DCP and D1208. Satisfactory progress is being made on emptying the first tank of intermediate waste liquor and incorporating it into a cement matrix contained in stainless steel drums.
10. The Caesium Removal Plant has continued to present problems due to blockage of the ion exchange resins. However, modifications have been made to the plant and tests are underway so that commissioning can continue.
11. A meeting has taken place involving DEFRA, DTI, NIREX, EA, SEPA and NII to discuss a proposed change in reference strategy for PFR raffinate from vitrification to cementation using a proposed new cementation plant, DCP2. Trials are underway as part of the development of the safety case for this change. However, until the safety case has been accepted vitrification will remain the reference strategy.
12. Following removal of bulk sodium from the PFR primary and secondary circuits, the sodium residue on surfaces will be removed by the Water Vapor Nitrogen (WVN) process. The process is being applied to cleaning of the sodium storage tanks and the secondary reactor circuits.
13. Previous reports noted significant slippage in DFR decommissioning and concern was expressed that further slippage could affect the declared DSRP milestones. A licence instrument has been issued for installation and testing of the DFR ventilation system but NII still has concerns with the development of the safety case for the NaK Disposal Plant. Removal of the NaK is a prerequisite for the removal of the stuck breeder fuel. NII is therefore being proactive in its interaction with UKAEA to ensure that progress is maintained.
14. As previously reported 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. UKAEA has put in place new measures such as root cause identification and now consider systems and behavioural matters. The NII investigation identified some improvements and these have been included in a letter to UKAEA. Further information will be provided to the LLC once NII's report is finalised.
15. Inspectors from the NII Dounreay team carried out a planned inspection of modifications across Dounreay site. Overall, based on the evidence of the sample inspection, the site showed generally good control of modifications. UKAEA has been progressing some areas for improvement identified by NII.
16. UKAEA has completed a site wide stress risk assessment and sent an interim report to NII with a final report due at the end of October. A number of areas have been identified as requiring improvement and an action plan is being drawn up. NII will review the plan, monitor its implementation and report progress to the LLC.
17. D2001 ILW Processing Facility
A licence instrument has been issued agreeing to the commencement of modifications to install a replacement Criticality Incident Detection and Alarm System (CIDAS). This was one of UKAEA's forward improvement commitments when the Consent for operation of the ILW plants was granted. The modification will replace the existing Mk 4 system with a modern BNFL Mk 10 system.
18. D1200 Laboratories
A licence instrument has been issued agreeing to the commencement of modifications to size reduce and dispose of redundant glove boxes in a number of laboratories within the D1200 facility.
19. D1203 Amber Area
As part of the ongoing POCO and decommissioning of the D1203 Amber Area, NII has agreed to the POCO of two vessels as an 'essential-to-safety' operation. The operations involve the transfer of a quantity of liquor from the two vessels and their subsequent washout. Completion of these operations will allow the next phase of decommissioning work to be progressed.
20. UKAEA has responded well to NII and FOD concerns outlined in the last quarterly report. The regulators are satisfied that UKAEA is the intelligent customer for contaminated ground matters undertaken by contractors and that improvements have been made to the system for producing safety documentation for asbestos work.
21. NII carried out inspections during this quarter on the following dates:
Inspection topics covered during the above visits included:
In general the inspection indicated that the site staff are satisfactorily managing and controlling the activities, and no significant issues were identified.
22. No improvement notices were issued during the period of this report
23. No events have occurred during the quarter that met the Ministerial reporting criteria.
24. D2580 Fissile Material Store.
Following the contamination incident in D2580 in March 2003 an embargo was placed to prevent any moves into or from the store. UKAEA has developed new safety procedures and the embargo will stay in place until the procedures are fully implemented and a new inspection system is in place.
(Note the embargo was lifted with NII agreement on 14 October 03).
25. NaK Fire Incident.
UKAEA has responded to NII concerns on the packaging and storage of NaK contaminated items (following the fire which occurred in February 2003). The embargo on the generation of further NaK contaminated wastes will remain in place until new procedures have been adequately implemented at PFR and DFR.
26. Contamination in PUMA Cell.
As reported in the last quarter, the NII investigation has been completed and a letter sent to Dounreay. The matters are now resolved and NII is content that UKAEA has learnt lessons from the incident.
27. Water Ingress Incident in PFR
NII is still monitoring the UKAEA response to the incident that occurred on 5th June 2003 in which water entered the ventilation ducting of PFR. This was discussed in the last NII report to the DLLC.
28. 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. NII is content that UKAEA has taken appropriate remedial action to improve supervision and the prompt reporting of incidents by contractors and project managers.
29. Worker contamination in D1204
Whilst undertaking decommissioning of a redundant hydraulic system in D1204 the former MTR reprocessing plant, two employees were contaminated on their hands and arms with radioactively contaminated hydraulic fluid. One employee could not be fully decontaminated that day and was sent home with gloves on. He was decontaminated the next day. Although a very small skin dose is likely, NII is concerned about the preplanning of the work and the possible stress implications for the employee who was not decontaminated on the same day. NII is monitoring the progress of the UKAEA investigation.
30. PFR Tank Farm Discharge
On 29th September, a quantity of caustic liquor containing tritium was discharged from the Sodium Tank Farm via the gaseous discharge system. Although the quantity of radioactivity released was below the notification level to NII specified in the Ionising Radiations Regulations, NII is concerned that the design of the plant allowed the accumulation and discharge of a hazardous liquid and is monitoring UKAEA's engineering improvements to the system. The incident is also being investigated by SEPA.
31. 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. The following Consents and Licence Instruments were issued during the period of this report:
Published on the HSE web site 4 December 2003