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.
1. The Site Inspectors and Specialist Inspectors visited Dounreay on the following days:
6 - 10 October,
17 - 20 November,
8 -11 December
2. NII Chief Inspector Laurence Williams visited Dounreay on 9 & 10 of October and received presentations on DSRP progress and a number of matters raised at his visit in 2002. Visits were made to inspect decommissioning in the FCA and in PFR. He welcomed the progress and commented that that there was a marked improvement with decommissioning since his last visit. He informed the site Director that he would invite UKAEA to give a presentation to the Health and Safety Commission on the decommissioning activities at Dounreay.
3. Management changes have now been implemented at SEPA. The NII site inspector met the new manager of the Radioactive Substances Unit to discuss the Memorandum of Understanding between the two regulators.
4. NII senior management has had high-level meetings with DTI and UKAEA on the UKAEA decommissioning programme. The meetings discussed priorities for each site and UKAEA put forward suggestions as to how they could make the most efficient use of their funding to meet their mission statement of "Restoring the Environment". NII is having further discussions with DTI and UKAEA on this matter.
5. The main thrust of NII activity during the period of this report has been inspection of compliance with Licence Conditions, monitoring of UKAEA investigations of incidents, the annual reviews of the DSRP, safety and emergency arrangements and the issue of a number of licence instruments for UKAEA operations and projects.
6. Inspection of the Dounreay site has continued as planned during the quarter.
7. Improvements to the arrangements identified from the 2003 Level l emergency exercise are being followed up during normal site inspection. NII considers that the site undertook a comprehensive set of site and plant exercises during the last year and that these exercises adequately tested the arrangements. The scenario for the 2004 Level 1 exercise was discussed and agreed.
8. The annual DSRP review meeting was held with the new Dounreay Director Norman Harrison in the chair. Overall the meeting went well but NII was concerned about a number of programme slippages. However, none of the strategic key milestones have needed to be revised. Interaction of the DSRP with the Life Cycle Baseline (LCBL) and Near Term Workplan (NTWP), developed for the Liabilities Management Unit of DTI, was discussed and it was agreed that the DSRP needs to remain in place. Further meetings will be held to ensure that the NTWP is compatible with the DSRP.
9. It was reported in the last quarter that NII had held discussions with UKAEA on the arrangements for the proposed PFI for the new conditioned waste store. PFI is now considered inappropriate for this type of project but NII has been assured that funding for this and other high priority projects will be protected at the expense of low priority work.
10. The site Director and senior managers along with NII superintending inspector and site inspectors attended the review. NII was satisfied with UKAEA's overall performance over the year during which significant improvements were made to the arrangements for maintaining safety related equipment and the introduction of a new plant modification system. The growing influence of the UKAEA Safety and Assurance Division was welcomed by NII, as was the report by the employee safety representative which was largely very positive especially about the recent managerial changes.
11. The FOD construction inspector Mr Black served an immediate prohibition notice for inadequate protection from a fall from height on a site construction project on the day of the meeting. He gave an explanation of the regulatory breach at the meeting and gave advice on future compliance with construction regulations. UKAEA has now improved arrangements and the notice has been complied with.
12. NII discovered during licence compliance inspection that the revised decommissioning safety case for PFR is not programmed for completion until July 2005 and that the 'current' safety case expired in June 2003. A Safety Approved Modification (SAM) had not been produced to extend the validity of the safety case. UKAEA agreed to stop operations except those essential to safety, until a SAM has been implemented. UKAEA also found another 14 safety cases that had expired including all Package Movement Safety Cases. SAMs have now been implemented for all the safety cases. The validity of a safety case does not appear to have been considered in the UKAEA annual safety review of each plant or area. Therefore, UKAEA has been asked to revise this procedure.
13. The Sodium Disposal Plant active commissioning programme has resumed following plant modifications to address the problems experienced with the resins in the Caesium Removal Plant. However, there remains an uncertainty over the mechanical life of the ion exchange medium. This will affect the total number of columns required.
14. The SDP is a high hazard plant from chemo-toxic aspects. Therefore, appropriate safety related equipment to guard against industrial/conventional hazards (e.g. acid spills, explosions, fires) is required. UKAEA has been informed that this will be an aspect which NII will scrutinise closely in the assessment of the safety documentation.
15. UKAEA has proposed changes to the ventilation of the Sodium Potassium disposal plant (NDP) that represents a significant improvement in terms of functionality and safety. The NDP Pre Construction/Commissioning Safety Report is now programmed for issue in April 2004. NII is monitoring progress closely as timely removal of the breeder fuel to Sellafield is a major strategic milestone.
16. Discussion is ongoing with UKAEA on the safety case for the breeder fuel removal including its seismic safety philosophy. UKAEA has been advised that an International Atomic Energy Authority Technical Document on seismic safety should be considered in relation to relevant good practice for systems, structures and components. However, NII has informed UKAEA that although the document is a relevant benchmark, the balance between risk and the cost of reducing the risk will be taken into account in assessment of of the safety case.
17. The Scottish Executive confirmed that it is content for the Drigg application to go to the final stage and SEPA has now initiated public consultation. This is welcome news as the site is running out of Low Level Waste storage space.
18. D1208 Liquid Effluent Storage and Treatment Plant
An internal visual inspection of Cell 7 in D1208 has confirmed that
the liquor level in the cell is above the usual level. UKAEA is
confident that the current liquor level is due to a water ingress
incident in August 2003. An assessment of the corrosion affects of
the liquor on the integrity of the cell is being carried out. A
report on the outcome of the assessment will be sent to NII including
proposals for future recovery operations.
19. D2700 Dounreay Cementation Plant (DCP)
Due to a blocked inactive drain line DCP was shutdown. The drain line
is used primarily for flushing out grout equipment. During excavation
work to investigate the blockage, contaminated ground was discovered.
UKAEA do not consider the drain to be the source of the
contamination, instead it is considered likely that the soil was
backfill used when the drain was constructed about 20 years ago. NII
has requested confirmation of this before we agree to the resumption
of operations at DCP. UKAEA are considering alternative arrangements
for handling the non-active effluents from DCP.
20. NII carried out inspections during this quarter on the
following dates:
7 - 9 October, and on
22 October to attend the Lone Star exercise planning meeting.
Inspection topics covered during the above visits included:
a. A routine visit by the Chief Inspector of the Nuclear
Installations Inspectorate.
b. The status of the Off Site emergency plan, which is now the
responsibility of the Highland Council.
c. Attending the Local Liaison Committee.
d. Risk Assessments and control of maintenance, under the Ionising
Radiation Regulations 1999.
In general the inspections indicated that the site staff are continuing to manage and control the activities in a satisfactory manner, and no significant issues were identified.
21. No improvement notices were issued during the period of this report
22. No events have occurred during the quarter that met the Ministerial reporting criteria.
23. Incidents reported to NII are included in quarterly reports to the Dounreay LLC and NII gives updates on progress of any significant recommendations from either their own or UKAEA's investigations. UKAEA has a database of incidents and their progress with close out of recommendations is inspected regularly by NII. The overall investigation performance of UKAEA is also considered at the NII - UKAEA annual review of safety.
24. During a non-routine operation to sample liquor from D1208 Cell 7 sump, approximately 0.75 m3 was inadvertently transferred to Tank 17 instead of being circulated through the sampling station and returned to Cell 7 sump. There were no radiological consequences associated with the event, as the liquor remained contained and shielded. The adequacy of UKAEA's investigation was questioned by NII and UKAEA has agreed to carry out a review of the investigation against their arrangements. UKAEA has also been requested to carry out a comprehensive review of hardware, software and administrative controls for liquor transfers, and to implement any identified improvements as far as reasonably practicable for minimising the risk of inadvertent transfers.
25. 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.
26. 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 Licence Instruments were issued during the period of
this report:
27. A licence instrument has been issued Acknowledging receipt of a
PSR for new dissolvers in D1203, and setting a regulatory hold point
prior to installation of the dissolvers.
28. A licence instrument has been issued Acknowledging the NaK Crust Characterisation Project Safety Document and notifying our intention to examine the safety justification which it provides for all operations involving disturbance of the Nak Crust, including taking the sample.
Published on the HSE web site 8 March 2004