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:
19 - 23 January,
9 -13 February,
8 -12 March,
22 - 26 March.
2. 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, review of the Near Term Work Plan (NTWP) and the issue of a number of licence instruments for UKAEA operations and projects.
3. Inspection of the Dounreay site has continued as planned during the quarter.
4. NII has formally agreed changes to certain dates in the DSRP
requested by UKAEA at the annual review meeting. The changes do not
however affect any of the key strategic milestone dates in the DSRP.
NII confirmed that the
NTWP programme schedule contained all the appropriate DSRP
milestones.
5. NII participated in a review of Dounreay's NTWP for the next two years led by the DTI Liabilities Management Unit (LMU). A separate session was held with the LMU to discuss regulator engagement in the process where it was agreed that in future earlier engagement with the regulators is required. The site achieved an overall score of 3 out of 4, and was commended on the very significant improvement since their presentation of the Life Cycle Baseline1 (LCBL1) last year. The most urgent review recommendation was for UKAEA to reconcile the funding discrepancy between what the NTWP requires and what will be available. NII will be participating in the development and review of the LCBL2 later this year.
6. A videoconference was held with the Dounreay Director on 17 March at which he proposed organisational change to give better focus on delivery of the forward decommissioning programme, details of which will be subject to a submission to NII under Licence Condition 36. The change will not involve an increase or decrease in overall staff numbers and there is to be no significant change to MPED. There does not appear to be any grounds to object in principle to these proposals, however Dounreay will need to go through their own due process and this should among other things provide assurance that nuclear safety functions would not the adversely affected.
7. A videoconference took place with UKAEA to discuss progress with the close out of the outstanding 27 medium term recommendations. UKAEA believe that they are ready to send about 10 requests for close out shortly. It was agreed that the close out procedure would be similar to that previously undertaken whereby there would be a review period that would allow for any new processes/procedures to be implemented. NII would undertake assessment and inspections as appropriate.
8. Initial discussions have taken place with UKAEA on the proposals in the Energy Bill to set up an independent police force. UKAEA is in the process of developing a submission to NII under Licence Condition 36 primarily because of the police's role in UKAEA's emergency arrangements.
9. A Consent to operate the Sodium Disposal Plant was issued on 12th March following NII's assessment of UKAEA's Pre-operational Safety and Commissioning Reports and after a pre-start up inspection of the plant. The Consent allowed the start of an eighteen month programme to destroy the bulk sodium coolant in the PFR vessel and in the Irradiated Fuel Cave facility.
10. DFR ventilation upgrade work has suffered a few months setback due to contractor problems. The main co-ordinating contractor has now left the site with UKAEA now performing the co-ordination function. The Pre Commissioning Safety Report for the ventilation upgrade will go the UKAEA Safety Working Party and then be submitted to the NII. The electrical supply improvements are also almost complete. All of this work is necessary to enable the plant to be decommissioned safely.
11. NII continues to monitor the development of the safety case for the construction and commissioning of the NaK disposal facility which UKAEA belive will shortly be sent to us for assessment. NII is also closely monitoring progress of the breeder fuel removal project because there is a narrow window of opportunity for the fuel to be sent to Sellafield before closure of B205 reprocessing plant.
13. Radiological Protection
NII has reviewed the UKAEA bioassay arrangements following a report
of an FCA employee being allocated a final dose of 8.6 mSv following
a long period of urine sampling. It would appear that UKAEA Dounreay
investigations into significant dose exposures are now adequate but
there have been some deficiencies in the past. As this employee has
now received 3 significant internal intakes, UKAEA's
recommendations to prevent further recurrences will be assessed very
closely by NII.
14. D1208 Liquid Effluent Storage and Treatment Plant.
UKAEA has submitted a report to NII on the high liquor level in Cell
7 including the assessment of the possible corrosion affects on the
integrity of the cell containment. The report concludes that there
are no significant corrosion effects and UKAEA proposes to evaporate
and store the liquor. The work did not proceed until NII assessed and
agreed the proposed recovery plan.
15. However, following a second inadvertent liquor transfer incident, all liquor transfer operations in D1208 were embargoed pending the outcome of a Dounreay Inquiry (DI) into the incident. During operations to empty the sumps of Cells 1 & 3 of water ingress, approx. 200 litres of liquor was inadvertently transferred to Storage Tank 3 instead of the Inlet Liquor Hold Tank. UKAEA agreed that no liquor or sump transfer operations would be carried out until arrangements were in place for independent verification of diverter settings and until improvements were made to the management control arrangements.
16. D2700 Dounreay Cementation Plant (DCP)
It was reported in the last quarter that due to a blocked inactive
drain line DCP was shutdown. UKAEA has reported that the blockage has
been cleared and DCP is working normally.
17. Dounreay has applied to enlarge the Nuclear Licensed Site Boundary slightly to encompass the proposed works for decommissioning of the Dounreay Shaft. NII is progressing the application and has received a positive response from the Scottish Executive on the subject of justification, clearing the way for the granting of the new licence. The most significant issue still outstanding is the lease to be granted by Crown Estates who own the land.
18. NII carried out inspections during this quarter on the
following dates:
11- 13 January, and on 2 - 4 March.
Inspection topics covered during the above visits included:
a. A presentation and 'workshop' covering the lessons learned
from other sites, in preparation for the 'Lone Star 04'
emergency exercise in May.
b. A review of the draft issue of the Off Site emergency plan, which
is now the responsibility of the Highland Council.
c. Attending the final planning meeting for Lone Star 04.
d. Attending the first planning meeting for the DELTA 38 emergency
exercise for the Dounreay Site, which will involve VULCAN
personnel;
e. A review of the site operator's On Site Emergency
Arrangements.
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.
19. No improvement notices were issued during the period of this
report
Incidents on Site
20. No events have occurred during the quarter that met the
Ministerial reporting criteria.
21. NII has voiced concerns to Dounreay senior management about
the gravity and frequency of incidents requiring investigations at
the highest level that are being held at the present time. We are
keeping a close watch on the outcome of these investigations, which
include the control of contractors in PFR, to ensure that the
recommendations are adequate to improve the situation. These matters
have also been discussed with the UKAEA Internal Inspection
Department which is carrying out its own investigation into the
control of contractors.
22. 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.
23. On the evening of 16th February, 40 scaffold poles were being
lifted from the ground floor of the PFR turbine hall to the 5th
floor. The load was dropped between the 3rd and 4th floors. There
were no casualties. A Dounreay investigation has been set up. UKAEA
notified HSE Field Operations Division who has responsibility for
regulation of non-nuclear safety on the site and they have advised
UKAEA that they wish to see the investigation report. The incident is
not reportable under Reporting of Incident and Dangerous Occurrences
Regulations (RIDDOR).
24. It was reported to NII that two fuel fragment particles were
found on site during a routine survey on 5th February. NII undertook
an inspection of a sample of areas designated as controlled and
supervised under Ionising Radiation Regulations 1999. Inadequacies in
the arrangements for the control of contaminated ground were
identified including standard of barriers, signage and general
housekeeping. These were subsequently discussed at a meeting also
attended by SEPA where UKAEA was actioned to review and improve
present arrangements for control and remediation of designated
areas.
25. In January, a Health Physicist noted irregularities in the
completion of leak test results for sources held at PFR and a local
investigation was initiated. The investigation found irregularities
in the records of the 2-year tests for several sources. Issues have
arisen with regard to suitably qualified and experienced persons,
supervision and control of contractors. All sources stored at PFR
have since been checked and found to be in acceptable condition. The
matter is being investigated by NII, and UKAEA has since initiated a
site wide investigation.
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 Consent and Licence Instruments were issued during the
period of this report:
27. A Consent was issued March to operate the Sodium Disposal
Plant.
28. A Licence Instrument has been issued agreeing to a modification for the cessation of a Criticality Detection and Alarm System requirements in the D1200 and D1215/18 laboratories.
29. A Licence Instrument was issued agreeing to the licensee proceeding with the taking of a Nak Crust Sample at DFR.
Published on the HSE web site 23 August 2004