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:
5 - 8 July
27 - 29 July
23 - 27 August
6 - 9 September
21 - 22 September
2. Peter Waller, Head of Coal and Nuclear Liabilities Unit, DTI, visited Dounreay on 6 and 7 July and received presentations on the main technical challenges facing the site, progress on the Dounreay Site Restoration Plan (DSRP), Life Cycle Base Line (LCBL), Near Term Work Plan (NTWP), and on preparations for the Nuclear Decommissioning Authority (NDA). A general site tour was undertaken followed by visits to the Prototype Fast Reactor (PFR), the Dounreay Fast Reactor (DFR), and a number of Fuel Cycle Area (FCA) plants. Mr Waller's observations on the site were generally complimentary and commented that staff are focused on the task of decommissioning and restoring the site.
3. NII Chief Inspector Laurence Williams, and Deputy Chief Inspector Andy Hall, visited Dounreay between 7 and 9 September and plant visits were made to the FCA, PFR and DFR. Mr Williams welcomed the progress that continues to be made on the site restoration He noted that the site is going through a transition period with the setting up of the NDA, however, Dounreay needs to remain focused on the day-to-day management of the site and delivery of the DSRP in a safe manner. He noted that the accelerated LCBL programme may put back a number of key strategic milestones. However, NII considers it important that the hazard reduction programme continues to be delivered to the commitments given in the DSRP.
4. Meetings were held in Inverness on 20 and 21 July to discuss issues relating to the contaminated land safety case and the site end state. A further meeting was held in Inverness on 29 September to discuss issues associated with the LLW strategy. Technical meetings were held at Risley on 7 September and at Halifax on the 23 September to discuss issues on the DFR ventilation upgrade project.
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, review of the DSRP and LCBL2, team inspection of quality assurance arrangements, review of a number of safety cases, and the issue of a number of licence instruments for operations and projects.
6. The planned routine inspection of the Dounreay site has been
reduced this quarter due to NII's involvement in LCBL 2.
Emergency Arrangements
7. This year the
national Level 3 exercise was held on 22 September 2004 and was
based on a hypothetical incident at Dounreay. The Site Inspector
participated at the site, and other NII staff were involved at
Inverness and Edinburgh. The exercise scenario was based around a
fire in D1203 that developed to the point where there was a release
of activity offsite requiring countermeasures. The primary purpose
of the exercise was to test the multi-agencies and national
response to a civil nuclear emergency in Scotland. There were no
significant problems with the site aspects of the exercise. UKAEA
is currently producing a report on the exercise that will identify
the lessons to be learnt.
8. Two formal triangular meetings were held to review progress on
the accelerated LCBL2. Attendees included representatives from
UKAEA, NII, Scottish Environment Protection Agency (SEPA), Office
for Civil Nuclear Security (OCNS) and DTI's Liabilities
Management Unit (LMU). NII commented that an earlier interaction on
the proposed accelerated programme would have been preferred. The
meetings discussed topics relating to progress on DSRP site
activities, update on LCBL2 and NII comments, fuel strategy,
prioritisation procedure, and management of change arrangements.
UKAEA is to provide more detail on the changes between the current
DSRP programme and the accelerated LCBL2 programme so that changes
in strategy are more transparent. UKAEA are also to arrange a
meeting to discuss the revised fuels strategy. Overall, the
meetings went well and were considered useful.
9. UKAEA proposed a
significant organisational restructuring at Dounreay to give better
focus on delivery of the forward decommissioning programme. The
change does not involve an increase or decrease in overall staff
numbers. NII examined the proposals in a licence condition 36
submission, and raised a number of issues that were discussed and
satisfactorily resolved with UKAEA.
HSE -SEPA 1998 Audit Medium Term
Recommendations
10. Overall, UKAEA progress on
closing out the 27 medium term recommendations has been less than
anticipated. NII requires UKAEA to have a well documented process
in place so that it can plan appropriate assessment of the close
out requests, and therefore NII asked for additional detail in the
close out justifications provided by UKAEA's Independent
Inspection Department. UKAEA has addressed this, and subsequently,
one of the recommendations has been closed out. UKAEA has provided
a programme for close out of the majority of the remaining
recommendations by March 2005.
11. Two of NII's specialist QA Inspectors carried out an inspection of Dounreay's QA arrangements. No Requirements were identified specifically for Dounreay, however, the inspection did refer to a corporate finding previously identified at Harwell. Overall, it was considered that Dounreay has made significant improvements to the QA arrangements since the HSE/SEPA Audit in 1998. The inspection provided 3 items of Advice for maintenance and improvement of the effectiveness of the internal QA audit system, although the management and implementation of the audit programme is considered to be of a high standard.
12. Dounreay has applied to enlarge the
Nuclear Licensed Site Boundary slightly to encompass the proposed
head works for decommissioning of the shaft. The marking of the new
site boundary has been delayed by protected species of nesting
birds on the foreshore. The other outstanding issue is the signing
of the lease to be granted by Crown Estates. This is now almost
complete and in anticipation of completion, a provisional date has
been set for the signing of the new licence by NII's Chief
Inspector. [Note: the new site licence was signed on
25 October 2004]
13. 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 LCBL2 and NII's
involvement in reviewing thes, resulted in slippage of the
programme. However, the programme of deliverables has now been
completed, and a formal Close Out meeting has been held. In
addition, UKAEA has submitted a Close Out Report to NII, and
requested a Consent to remove the restrictions on operations
imposed by the Direction and to return FCA operations to normal
regulatory control. NII has examined the safety documentation, and
as a result, expects to be able to issue a Consent in the very near
future. [Note: the Consent was granted on 4 October 2004]
14. Following the occurrence of a number of incidents at PFR with potentially high consequences early in 2004, UKAEA suspended all operations (except those essential for safety and operation of the Sodium Disposal Plant), and carried out an investigation to identify the problems. The review identified a number of improvements at PFR including, changes to the management structure, control of contractors, clarification of supervisory roles and work control. 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 continues to be closely monitored by NII.
15. The sodium destruction plant for removing bulk sodium from the
PFR reactor is performing well. On completion of the removal of the
bulk metal, UKAEA propose to remove the remaining residual layer of
sodium by the Water Vapour Nitrogen (WVN) process which is
currently under development by UKAEA and the AMMR Alliance. NII has
been monitoring this development work closely and, because of the
hazardous nature of the process and the unique application, has
decided to formally 'call-in' for examination the safety
documentation for PFR reactor vessel work.
DFR Decommissioning
16. The validity of the DFR Decommissioning Safety Case (DSC)
expired at the end of August 2004. UKAEA raised a modification to
extend the DSC until a revised DSC is produced that is linked to
the Breeder Fuel Removal project. NII has examined the safety
documentation and has accepted UKAEA's proposal.
17. NII's assessment of UKAEA's safety case supporting an
agreement for construction of the DFR NaK Disposal Plant continues.
A number of specialist technical issues have been raised that are
currently being addressed by UKAEA.
18. A meeting was held in Inverness on 29th September to discuss UKAEA Dounreay's strategy for the management of Low Level Waste. The meeting was also attended by LMU and SEPA. UKAEA set out the basis for a long term management strategy covering waste minimisation and segregation, disposal of suitable waste to Drigg (given the granting of an Authorisation from SEPA) and the potential need for a disposal facility at Dounreay. Decisions need to be taken by NDA and Government (DEFRA) before the strategy can be advanced in some areas. NII has agreed that UKAEA should continue to develop this strategy.
19. A meeting was held
with UKAEA to discuss the contaminated land safety case, and as a
result, NII are to monitor the implementation plan and forward
improvement programme. The Dounreay site has a number of outside
areas that are designated as controlled areas under the IRR's
and where fuel particles have been found. NII considers that
improvements are required to the containment of these controlled
areas, particularly to prevent the intrusion of wildlife, and has
recently received details of improved arrangements.
Solid ILW Project
20. The SILW project is a
multi-stage, long term project, and UKAEA have agreed to produce an
up to date Safety and Environment Overview Report (SEOR). The SEOR
will indicate the type and timing of safety, environmental and
planning application documentation required for the various sub
projects of the overall SILW project. This should assist in
eliminating future problems with the coordination of the various
activities associated with the project.
21. Following two inadvertent liquor transfer
incidents, UKAEA have carried out a review of the controls
associated with liquor transfers in D1208, with the intent of
implementing any reasonably practicable improvements. NII considers
that the review was comprehensive with regard to hardware controls,
but that additional work needs to be done on the review of software
and administrative controls. Also, NII has asked UKAEA to provide a
programme for implementing the improvements.
UKAEA has already implemented a number of administrative
improvements for the control of liquor transfers, including
independent verification of diverter valve settings and improved
operating instructions.
22. NII carried out
inspections at NRTE VULCAN, during this quarter on the following
dates:
6 July
10 - 12 August
7 - 8 September.
Inspection topics covered during the above visits included:
a. The Chief Inspector of the Nuclear Installations Inspectorate
visited the site as part of his routine inspection programme. He
stated he was content with what he found;
b. Attendance at the Emergency Planning Co-ordinating Committee of
the Dounreay Local Liaison Committee which reviewed the
arrangements at the site following the Lone Star 04 exercise;
c. Inspecting the site's compliance with the requirements of
regulations 7, 8, 14, 21, and 28 of The Ionising Radiations
Regulations 1999 (IRRs). No significant issues were raised.
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.
23. No improvement notices were issued during the period of this report
24. No events have occurred during the quarter that met the
Ministerial reporting criteria.
25. 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.
26. On 27 July, a hot gas release occurred from a redundant sodium
contaminated vessel during cutting operations into the vessel. An
emergency was declared and HSE notified. HSE's Hazardous
Installations Directorate (HID) and NII have since been
investigating the incident. As a result, it seems likely that HID
will serve Improvement Notices on both Alstec and UKAEA. In
addition, a previous incident which occurred during Water Vapour
Nitrogen operations at Janetstown, is also being investigated. Both
events have implications for similar work carried out on the
Dounreay site, and until investigations are completed and
improvements implemented, similar operations at Dounreay have been
embargoed by UKAEA.
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 Licence Instruments were issued during the period of
this report:
28. A Licence Instrument has been issued Agreeing to the
construction of the Dounreay Cementation Plant Import Export
Facility. NII does not intend to impose any further regulatory hold
points on the subsequent stages of this project.
29. A Licence Instrument has been issued Agreeing to the
implementation of UKAEA's proposals for the reorganisation of
Dounreay. UKAEA are to provide
2 monthly progress reports to NII, and to submit the findings of
their audit on the implementation of the reorganisation.
30. Following a review of the D1215/1218 Laboratories modern standards safety case and the resolution of a number of NII issues, a Licence Instrument has been issued acknowledging the safety case. NII has decided that there is no need for detailed assessment of this particular safety case.
Published on the HSE web site 03 January 2004