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.
NII inspectors visited Harwell on 16 days this quarter:
12 - 14 January Site inspection
23 - 26 February Site inspection; Annual Review Meeting; reactive
inspection
22 - 24 March Fire safety inspection; visit to Western Storage
Area
The milestone for the feedback of the findings of the NII assessment of the Harwell SW-PSR Submission was achieved on time with a presentation and discussion with UKAEA held on 8 April 2004. UKAEA has requested some clarification of a number of the issues and UKAEA and NII are working towards agreeing an appropriate forward improvement programme ready for the decision milestone scheduled at the end of June 2004. NII has started to prepare a report of the assessment for public issue which is due to be published no later than December this year, as defined by current NII guidance.
Key issues continue to be discussed with the Environment Agency. Included this quarter was the review of UKAEA's Near Term Work Plan for Harwell. This matter is reported separately below.
NII participated in the Harwell Annual Review of Safety Meeting. This included a review across all of the main aspects of site operations. This meeting was well organised with advance papers to a good standard and on time, and with positive contributions from all participants including tenants and safety representatives.
Licence Condition (LC) Compliance inspections
LC3 Restrictions on dealing with the site
UKAEA and NII explored the issues associated with various applications for Consent submitted under LC3, to enable UKAEA to lease facilities to prospective tenants. The visit helped clarify the position on the existing and future leasing applications, and enabled agreement to some improvements to UKAEA and NII processes for managing lease applications. Good progress was made.
The public can be exposed to ionising radiation from nuclear licensed sites from various means: direct radiation from site operations is one means. The licensee is responsible for controlling exposure to direct radiation from Harwell. HSE regulates exposure to direct radiation, and does so by monitoring the licensee's arrangements and by taking independent measurements. These measurements are carried out on a rolling programme, and Harwell was visited in March 2004 for this purpose. The results from these measurements will be covered in a later report to the LLC.
Independent measurements of direct radiation from Harwell were last made in late 1998. The results showed that the highest does rates were well below the legal dose limit, and well below the dose constraint set by the National Radiological Protection Board.
Consideration was given this quarter to UKAEA's Near Term Work Plan for 2004 (NTWP04), a comprehensive document that itemises and resources all site work in the form that will be required by the Nuclear Decommissioning Authority (NDA). UKAEA's NTWP04 was presented as a single UKAEA Plan since its intention is to remain as a single contracting body under NDA. Due to delivery timescales there was insufficient time available for NII to review NTWP04 in detail prior to the reviews carried out in March by DTI's Liabilities Management Unit (LMU). NII did however provide UKAEA, in early February 2004, with a listing of regulatory requirements for inclusion within the scope of NTWP04. The site inspector carried out a sample inspection of these requirements and concluded that NTWP04 addressed them satisfactorily.
In its Site Reviews, LMU made a number of recommendations, including the need for earlier engagement with the regulators for NTWP05. The potential non-availability of waste disposal routes was identified as a project risk for most of the decommissioning projects: LMU's position was that the licensees should look for innovative solutions for dealing with such waste streams.
NII carried out an inspection of B459, in support of its assessment of the revised Operational Safety Case for B459. The inspection also served as an example of NII's assessment of UKAEA's engineering substantiation with respect to the Site-Wide Periodic Safety Review. The inspection concentrated on the safety of operations in the high-active cell line. NII has since written to UKAEA seeking early implementation of additional engineered safeguards to complement existing strengthen management controls, and to complete the design and installation of proposed interlocks.
During our visit NII noted several examples of housekeeping standards that were not fully adequate. UKAEA quickly acknowledged the inspection findings and took steps to resolve the matters quickly.
At the end of December 2003 UKAEA embargoed in B462.27 the use of flasks used to transport radioactive material, because the flask lift height appeared to exceed the limit specified in the flask safety case. The embargo prevented UKAEA from continuing to retrieve ILW, an important operation for Harwell. The site inspector agreed a way forward for the short term involving the implementation of revised management arrangements which limit the operational lift height whilst still enabling waste retrieval to continue. In the longer term NII will require further substantiation of the safety of flask operations in B462, to include the use of engineered safeguards where appropriate. Progress on this issue will be reported next quarter.
The incident occurred when an operator in B466 attempted to lift from the bottom of the pond what he thought was an empty source basket - in fact it contained several highly radioactive sources. A gamma monitor alarmed and the basket was lowered to the bottom of the pond. The operator was found to have been exposed to a whole body dose of 100 micro Sieverts 1; but the dose could have been worse and so the incident was considered as a serious near miss. UKAEA's investigation, in conjunction with the tenant (REVISS), was considered to be of a high standard and reported quickly. It concludes that the fault sequence of lifting a basket holding a source was not properly addressed; and the relevant operating rules and engineered safeguards were not fully adequate. NII's investigation will continue and will be covered in next quarter's report.
The site inspector reviewed UKAEA's state of readiness for extending the validity of the safety case of B220 until December 2005, to allow UKAEA sufficient time to prepare a revised modern standards operational safety case (OSC). It was concluded that there was nothing of significance to prevent the issue of a Licence Instrument (LI) accepting UKAEA's safety case, and the LI was signed on 5 March.
NII considered a request by UKAEA to down-grade the safety category of building B393.6 from Category 2 to Category 3 2. B393.6 was formerly a facility for post-irradiation and examination of fissile and non-fissile materials. The facility was closed in 1995 and since then it has been undergoing decommissioning with a view to final demolition, and the majority of the radioactive inventory has been removed. NII raised no objections to UKAEA's request and the Licence Instrument accepting UKAEA's safety case was signed on 5 March.
NII commissions radiological survey work to confirm the Licensee position that there is no danger from ionising radiations from anything on that part of the site that is proposed for delicensing. The National Radiological Protection Board (NRPB) undertakes these surveys. NRPB has completed the necessary work at Harwell on behalf of NII. NII is awaiting the formal submission of NRPB's final report.
The HSE Fire Surveyor, carried out an inspection for compliance with the Fire Certificates (Special Premises) Regulations 1976. The existing Fire Certificate was examined, and visits made to several facilities that are the subject of applications by UKAEA to amend the Fire Certificate. Generally the Fire Surveyor raised no major issues, though he advised UKAEA on improvements that need to be put in place. A programme of future visits was agreed to inspect all facilities on the site, with a view to reissuing the Fire Certificate.
An NII conventional safety specialist carried out a preliminary inspection of the Western Storage Area (WSA) 3. The site boundary was found to be well fenced and signed, with additional fencing erected to ensure that persons cannot get close to the work area. Welfare provisions for site staff are satisfactory. An extensive set of on-line monitoring stations has been established around the site, to enable early detection of any release of hazardous gases which might arise from the recovery operations. Workers close to the pits will be protected by suitable protective equipment. UKAEA's control and supervision of subcontractors was questioned with regard to the standards of safety of equipment brought on the site: UKAEA and its contractor are to implement procedures to counter this possibility. A second visit is planned.
NII has powers under the Nuclear Site Licence to issue Consents, Approvals and Directions. In addition, NII uses Licence Instruments to issue Specifications, Acknowledgements and Agreements under the conditions attached to the Licence, or under arrangements made by UKAEA for complying with those conditions.
During the period of the report, no Consents, Approvals or Directions under conditions attached to the Site Licence were issued.
Two Licence Instruments were issued:
Licence Instrument No 69, dated 5 March 2004, Site Licence No 44. Acknowledgement of receipt of a category A modification to justify the continued operation of B220 until December 2005.
Licence Instrument No 70, dated 5 March 2004, Site Licence No 44. Acknowledgement of receipt of a category B modification to recategorise B393.6.
1. The Ionising Radiations
Regulations 1999 define the annual whole body dose limit for a
radiation worker as 20 milli Sieverts, or 20,000 micro
Sieverts.
2. Under UKAEA definitions, Category 2 facilities have the potential
to give rise to a significant on-site (but not off-site) radiological
hazard; Category 3 facilities can give rise to a significant
in-building (but not on-site) radiological hazard.
3. The WSA site was licensed by Oxfordshire County Council and was
used between the late 1960s up to 1996 for the storage, treatment and
disposal of various chemical wastes. There is no radioactive hazard
at the WSA. Over a period of time the WSA has given rise to
groundwater contamination which UKAEA is controlling via groundwater
extraction equipment. UKAEA plans to remove the wastes for off-site
disposal at licensed facilities. This will remove the source of
ground water pollution. A later project will remediate contamination
of the underlying rock.
Published on the HSE web site 14 June 2004