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:
20 - 23 and 27 - 30 April
11 - 14 May
15 - 17 and 22 - 25 June
2. A French regulator delegation visited the site to gather information about radwaste management and decommissioning. The delegation was particularly interested in the PFR Sodium Disposal Plant (SDP) because Electricite de France (EDF) has planned to build two similar facilities for decommissioning French reactors of the same type as PFR. The delegation reported that the visit had been well worthwhile.
3. A meeting was held in Manchester on 25 May to discuss progress with the Dounreay Site Restoration Plan (DSRP) and Life Cycle Baseline 2 (LCBL2). Technical meetings were held at Risley on 24 and 25 June to discuss issues on the DFR NaK Disposal Plant and on the DFR Breeder Fuel Removal project. A further meeting was held at Risley on 28 June to discuss issues relating to the Dounreay re-organisation.
4. 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 DSRP and LCBL2, team inspection of records, planning and observation of the annual demonstration emergency exercise, review of a number of safety cases, and the issue of a number of licence instruments for operations and projects.
5. Inspection of the Dounreay site has continued largely as
planned during the quarter.
Emergency Arrangements
6. The Dounreay Level 1 annual demonstration emergency exercise
was held on
13 May 2004. The exercise scenario was based around a 25 tonne
fork-lift truck colliding with the corner of a storage tank at D1208,
resulting in damage to the building fabric and a release of
radioactive material to the environment. The exercise tested the site
arrangements for setting up the various incident control centres,
mustering of personnel, establishing local containment of the leak,
recovery and treatment of casualties, and producing a viable recovery
plan.
Overall NII judged the exercise to be a successful demonstration of UKAEA Dounreay's emergency arrangements. The key lesson to be learned relates to improved welfare of sheltering staff in the outlying areas of PFR and DFR.
7. The annual review of the DSRP was attended along with
representatives from the Scottish Environment Protection Agency
(SEPA), the Office for Civil Nuclear Security (OCNS) and DTI's
Liabilities Management Unit (LMU). This was the first formal meeting
between UKAEA and these parties to discuss the
acceleration of the DSRP/LCBL programme to 2047. NII commented that
an earlier interaction on the proposed accelerated programme would
have been preferred. The meeting discussed topics relating to
progress on DSRP site activities, update on LCBL2, prioritisation
procedure, and site end state. Overall, the meeting went well and was
considered useful. A further meeting to discuss in more detail the
accelerated DSRP/LCBL programme was set for 8 July 2004.
Organisational change
8. UKAEA is proposing a significant organisational restructuring
at Dounreay to give better focus on delivery of the forward
decommissioning programme. The change will not involve an increase or
decrease in overall staff numbers. NII has no objection in principle
to the proposed changes, but has examined the proposals in some
detail and raised a number of issues. These have been discussed with
UKAEA who have responded to them. These responses were reviewed by
NII and there appeared to be no major obstacles to NII agreement to
the changes.
HSE -SEPA 1998 Audit Medium Term Recommendations
9. UKAEA has sent NII close out requests for a further 7
recommendations
(making a total of 10 out of 27). NII requires a well documented
process in place to so that it can plan appropriate assessment of the
close out requests. NII has asked for an additional level of detail
in the close out justifications provided by UKAEA's Independent
Inspection Department. UKAEA is addressing this, and has submitted
one revised close out request that NII is currently reviewing.
10. NII carried out an inspection at Dounreay as part of a series
of inspections of
UKAEA's arrangements for the management of health and safety
related records, including operational records. The Inspectors noted
that significant improvements have been made since the 1998 Dounreay
Audit, and that overall, a generally satisfactory standard of records
was found. However a number of
Requirements and Advices were issued to achieve further improvements
in some areas.
11. Dounreay has applied to enlarge the Nuclear Licensed Site Boundary slightly to encompass the proposed head works for decommissioning of the shaft. The most significant outstanding issue is the lease to be granted by Crown Estates, and UKAEA has experienced difficulties arranging a meeting with the Crown Estates Office to finalise the wording of the lease. As a result the signing of the new licence by NII's Chief Inspector has been delayed.
12. In May 2003 a programme of deliverables for lifting the Direction
was agreed with UKAEA Dounreay senior management. UKAEA priority work
on producing NTWP04 and NII's involvement in reviewing it,
resulted in slippage of the programme. However, the programme of
deliverables is now nearing completion, and a formal Close Out
meeting has been held to determine the current timescales for lifting
the Direction. UKAEA is now embarking on the final part of the
process and is currently producing a Close Out Report for submission
to NII. The target date for granting a Consent to lift the Direction
is now September 2004.
13. Following the occurrence of a number of incidents at PFR with potentially high consequences, UKAEA suspended all operations (except those essential for safety and operation of the Sodium Disposal Plant). The root causes were considered to be associated with control of contractors, lack of clarity in supervisory roles and problems in work control. UKAEA carried out a review of the situation at PFR covering safety documentation, work control arrangements, supervisory arrangements, resourcing, interfaces between UKAEA and contractors and delegation of responsibilities. The review identified a number of improvements, including changes to the management structure at PFR, and these are being implemented against a programme for restarting operations. NII believes UKAEA responded appropriately to the occurrence of incidents, nevertheless the situation at PFR will continue to be closely monitored by NII.
14. UKAEA has now submitted the long awaited revised safety case for
the DFR NaK Disposal Plant (NDP). Assessment of this has been treated
as important by NII. A meeting has taken place with UKAEA to discuss
NII's initial
assessment issues, and at which UKAEA presented details of the DFR
management changes, and progress with the DFR Ventilation Upgrade
project.
15. A meeting took place with UKAEA to discuss progress on the
Breeder Fuel
Removal project at which UKAEA presented updates on the project scope
and safety case. A number of key assessment areas were discussed
covering seismic criteria, Goliath crane safety case, dose uptake
assessment, human factors and security.
16. UKAEA has submitted the final version of the BPEO for long-term disposal of LLW. A triangular meeting was held between the regulators (NII & SEPA), UKAEA and LMU to discuss LLW strategy, progress on the LLW to Drigg application, and the timing and content of the publication of the LLW BPEO and LLW strategy. With regard to the application by UKAEA to send LLW to Drigg, the public consultation by SEPA is complete and SEPA is now in the process of determining the application. SEPA is keeping NII informed of progress as the opening of the Drigg disposal route is a recommendation from the 1998 Dounreay Audit, and is a key part of the site's LLW strategy.
17. The contaminated land safety case has been received and a meeting has been arranged on 20 July in Inverness to discuss its contents, implementation plan and forward improvement programme. A linked meeting will also be held to discuss UKAEA's latest proposals for the progression of the strategy for the site end state. This issue has assumed increased importance now that UKAEA is proposing to accelerate the site decommissioning.
D1208 Liquid Effluent Storage and Treatment Plant.
18. Following NII assessment and acceptance of their proposals, UKAEA has now evaporated and transferred the liquor in one of the cells to one of the Storage Tanks. UKAEA has carried out improvements to prevent any future water ingress into the cell.
19. Following the two inadvertent liquor transfer incidents, UKAEA has implemented improved administrative arrangements for the control of liquor transfers, including independent verification of diverter valve settings. UKAEA has also completed a major review of the hardware, software and administrative controls associated with liquor transfers in D1208, with the intent of implementing any reasonably practicable improvements. A report of the review has been produced and is due to be submitted to NII for assessment.
20. Following the submission of a LC36 Management of Change proposal,
NII agreed to the introduction of 24 hour shift working at DCP. The
objective of the change is to enable the cementation of MTR raffinate
to be completed earlier than originally programmed.
Vulcan NRTE
21. NII carried out inspections at NRTE VULCAN, during this
quarter on the following dates:
27 - 29 April
25 - 27 May.
Inspection topics covered during the above visits included:
a. Attendance at the Dounreay Local Liaison Committee, in conjunction
with staff from the Ministry of Defence regulator.
b. Inspecting the site's compliance with the requirements of
regulations 19, 21, 25, 28, and 30 of The Ionising Radiations
Regulations 1999 (IRRs). No significant issues were raised.
c. Attending and assessing the adequacy of the Off Site emergency
arrangements, in conjunction with Ministry of Defence regulator,
during the Lone Star 04 exercise. It was considered to be a
satisfactory test of the arrangements provided by the Highland
Council, as required by the Radiation (Emergency Preparedness and
Public Information) Regulations 2001 (REPPIR).
d. Attending the regular meeting of the The Emergency Planning
Co-ordinating Sub-Committee of the DLLC, which included a review of
the emergency arrangements for the VULCAN and Dounreay sites as a
result of the Lone Star 04 Exercise.
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.
22. No improvement notices were issued during the period of this
report Incidents on Site
23. No events have occurred during the quarter that met the
Ministerial reporting criteria.
24. 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. Following discussions on contaminated
land, UKAEA has agreed to formally notify NII of any on-site particle
finds.
Investigation into Dose Intake in FCA Plants
25. As a result of a 8.6 mSv intake in 2003, UKAEA has made recommendations to improve bio-assay sampling. The review also looked at means of prevention in the shape of improved engineering controls, supervision and task based risk assessments, and the need to adhere to such measures more closely will be detailed in a site briefing. NII will continue to monitor the impact of the improvements as part of normal regulatory business.
26. There has been a series of Lost Time Accidents caused predominantly by manual handling issues. These accidents have occurred at D1203, WRACS, D1217, PFR, DFR and D8525 (main stores). UKAEA has reviewed these accidents and concluded that a common key causation factor is that managers and supervisors are not always following the site arrangements for risk assessment in relation to non-nuclear hazards. To rectify the deficiencies UKAEA has formulated an Action Plan that is currently being implemented. NII will monitor the implementation of the Action Plan and continue to monitor UKAEA's performance in this area.
27. 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:
28. A Licence Instrument has been issued Agreeing to the Package
Movement Safety Case for the Z6016 Flask. This will allow the
transfer of ILW from PFR to the D9875 store to commence.
29. A Licence Instrument has been issued Acknowledging receipt of the new facility safety case for D2001. NII does not intend to carry out a detailed assessment of this safety case.
30. A Licence Instrument has been issued to allow UKAEA to begin
man entry
decommissioning operations in the Pulsed Column Lab glovebox.
Published on the HSE web site 11 October 2004