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 the UKAEA Harwell licensed site. 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 Site Inspector visited Harwell on the following days:
| 28 April | - | 1 May | Team Inspection, Compliance with LC22 (Modification or Experiment on Existing Plant) | ||
| 19 May | - | 22 May | Visit by NII Chief Inspector Site inspection and familiarisation | ||
| 9 June | - | 12 June | Site Inspection |
The site inspector and colleagues spent a total of 22 man-days on site.
Mr P S Watson became Harwell nominated site inspector on 1 April 2003. Handover visits to both Harwell and Windscale (Mr Watson's previous area of responsibility) were undertaken during the quarter.
On 1 June NII appointed Mr Watson as nominated site inspector for Winfrith, in addition to Harwell, following the transfer of the previous site inspector (Mr I K Gibson) to other NII inspection duties. In future Mr Watson will aim to spend around 80% of his time on Harwell matters and 20% on Winfrith (with other inspectors providing around 40% of effort on Winfrith). NII considers that the revised allocation of resource is justified by the reducing radiological challenge posed by UKAEA Southern Division sites, notably Winfrith. The changes mean that NII inspectors will have less time to devote to Harwell and Windscale, but this will be offset by improved team working and the greater use of administrative staff for process-based operational issues. NII has discussed the changes with UKAEA and both parties will undertake monitoring to ensure the continuation of effective and efficient regulation of all three UKAEA Southern Division sites.
The LLC will already be aware that UKAEA has undertaken a safety review at Harwell, under their arrangements made for compliance with Licence Condition 15 (Periodic Review). The overall objective is for UKAEA to satisfy NII that an appropriate framework exists so that the site can be operated safely up to the time of the next review (due in 10 years). This is a global review of the entire site safety arrangements, and should incorporate the lessons learned from the Safety Audit at Dounreay in 1998; it is the first time that a global site review has been undertaken on UK nuclear installations. NII has now received the document, on time and to an adequate standard for assessment. NII will assess the document to verify the process undertaken and the suitability of the recommendations.
Key issues continue to be discussed with the EA inspector. Included were the proposed Consent for the assignment of the lease for B466, the proposal to transfer the Fingal Flask from B462 to B459, and discussions on future joint inspection activities.
Mr Williams, accompanied by Mr D Buchanan (Chief Executive, Health and Safety Laboratories) visited Harwell on 22 May, as part of Mr Williams' rolling programme of visits to licensed sites. UKAEA made presentations on the site strategy and the B220 Exit Plan, and they toured several facilities including B462, B220 and GLEEP. The visit served to illustrate the challenges facing Harwell and the progress that has been made. Mr Williams commented favourably on the competence and commitment of the people he had met.
Three inspectors from ND 3c carried out a planned inspection of modifications across Harwell. This was the second of a series of inspections planned to be conducted across all four UKAEA licensed sites. The inspection confirmed the findings from the equivalent visit to Windscale, that UKAEA's arrangements for modifications are not fully adequate. UKAEA had already recognised this and was taking action, but at the time of the inspection Harwell could not fully demonstrate compliance with licence conditions. We also noted that, whilst each facility visited demonstrated generally adequate control of modifications, there was considerable inconsistency between them.
The site inspector also participated in the equivalent inspection of Winfrith in May, and Dounreay was inspected in June. NII will be producing an overview report shortly.
Inspection of safety case issues associated with B466 was undertaken, in relation to UKAEA's application to assign the B466 lease from AEAT to REVISS. It was concluded that the safety case and UKAEA's demonstration of compliance with it could be improved, but nothing arose which might delay issuing the Consent. The lease assignment will improve visibility of control and should make it easier to bring about improvements. The LC3 Consent was signed on 24 June.
The site inspector considered the project to transfer the Fingal Flask so that the vessel within it, containing vitrified waste, can be processed prior to interim storage. The first stage of the project involves transferring the Flask from B462.20 to B459 and unloading the vessel into B459. The Flask can then be decontaminated and qualified to transport the remaining six Fingal Vessels. The work was considered to be justified and the approach that UKAEA wishes to adopt appeared reasonable. However improvements to the safety documentation were requested and UKAEA is to provide further details. The work is expected to be completed in July.
NII has already reported to the LLC that UKAEA wishes to consider the possibility of a Private Finance Initiative (PFI) for plants that will be required for conditioning of retrieved waste, both at Harwell and elsewhere. NII does not, in principle, object to the use of PFI contractors, providing such use does not jeopardise health and safety or the continued capability of the licensee to meet its obligations under the nuclear site licence. Constructive dialogue has taken place that has helped to highlight and understand the areas of concern within the regulatory framework. Since PFI is a generic issue UKAEA is developing a corporate proposal. NII is also managing PFI on a generic basis and is preparing a guidance document for licensees and potential PFI contractors.
During the period of the report, no Approvals or Directions under conditions attached to the Site Licence were issued. The following Consents were issued;
Consent No 96. Lease of Building B418.14 to AEA Technology plc, dated 3 April 2003.Consent No 97. Lease of Part Building B424 to RWE Nukem Ltd, dated 3 June 2003.
Consent No 98. Assignment of the Lease of B466, from AEA Technology to Reviss Services (UK) Ltd, dated 24 June 2003.
The following Licence Instrument was issued;
Licence Instrument No 66. Acknowledgement of a category B modification under the arrangements made for LC22 for operations involving receipt and storage of Dragon fuel at Harwell, dated 29 May 2003.Published on the HSE web site 18 August 2003