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 20.5 days this quarter:
1 April Criticality inspection of B462.23
6 - 8 April Site-Wide Periodic Safety Review close-out meeting
Enhanced inspection, LC6 & 25 (Records)
Reactive inspection, B466 dropped basket incident
12 - 14 May Enhanced inspection, LC17 (Quality Assurance)
25 - 26 May Regulatory forum meeting, Life Cycle Baseline 2
15 - 17 May B462 safety cases, flask transport safety case
Formal feedback of the NII assessment recommendations on the Harwell SW-PSR submission was achieved on time in March 2004 and the findings have essentially been agreed with UKAEA. NII is drafting a report which is intended to be published before the end of the year. NII accepts that the SW-PSR submission is satisfactory to justify continued operation of the Harwell site and its facilities for the near future, subject to producing and implementing a forward improvement programme over the next two years. A primary aim will be to finish the outstanding Modern Standards Safety Cases for Harwell facilities.
Key issues continue to be discussed with the Environment Agency. Included this quarter was the review of UKAEA's Life Cycle Baseline for Harwell: this matter is reported separately below.
LC6, Documents, records, authorities and certificates; LC25, Operational records
NII has carried out a series of inspections across UKAEA's licensed sites of arrangements for the management of health and safety related records. The Harwell inspection was conducted in April. Generally compliance with LC6 and 25 was found to be satisfactory, though NII identified some areas for improvement including tenants' arrangements, facility local document storage and record retention schedules.
LC17, Quality Assurance (QA)
An inspection for compliance with LC17 was carried out at Harwell, as part of NII's rolling programme of LC17 inspections. Generally good standards of QA were found during the inspection, particularly in Procurement where the contract strategy sampled was regarded as best industry practice. There were also some areas for improvement, notably the need for a process-based integrated management system. NII will finalise its report once a similar inspection at Dounreay is carried out.
NII participated in the first Regulatory Forum meeting (comprising representatives from UKAEA, Liabilities Management Unit and the regulatory bodies) to discuss the preparation of the second version of Harwell's Life Cycle Baseline document, referred to as LCBL2. We explored the projects covered by LCBL2 and the underlying assumptions. This was the first of a proposed series of meetings involving UKAEA, LMU and the regulatory bodies.
The site inspector considered a UKAEA modification for the receipt and storage of Winfrith low enriched uranium (LEU) at Harwell B462.23. As part of NII's assessment of this proposal, a criticality specialist visited both Harwell and Winfrith and concluded that he had no objection to the project. Discussions were held as to the implications of the project for the long term adequacy of the Harwell radwaste strategy. Overall, NII concluded that the modification proposal was tolerable, taking into consideration the significant benefits to Winfrith of completing the transfer of LEU.
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. During the quarter the embargo remained in place for one particular flask type, known as Graviners. NII recognises that the embargo is delaying the recovery of waste so that it can be immobilised and stored safely, and is working with UKAEA to arrive at a satisfactory safety case to enable the embargo to be lifted.
Related to the B462.27 flask embargo is a series of related safety cases received for NII consideration: the B462.27 vault store Pre-Operational Safety Report (POSR); the B462 Retrieval Machine POSR; and the request to extend the period of validity of flask Package Movement Safety Cases. A team from NII met UKAEA to discuss these safety cases and undertake a facility inspection visit. The meeting also helped to develop issues arising from NII's assessment of the Site-Wide PSR in relation to the transport of radioactive material.
The site inspector participated in the annual Emergency Exercise Review Meeting. The discussions included progress on the development of a new corporate standard for compliance with LC11 (Emergency Arrangements), progress with the actions from the previous Level 1 exercise , and the outline plans for the next L1. UKAEA announced that the proposed L2 exercise in May is to be cancelled because of delays with completion of improvements to the off-site facility at the Thames Valley Police Headquarters, Kidlington. UKAEA has written to NII to justify that most of the various aspects associated with a L2 exercise have already been covered, albeit on a modular basis, and a revised date for the L2 is being considered.
This incident occurred when an operator in B466 (operated by REVISS Services (UK) Limited as tenant of UKAEA) 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 3 ; but the dose could have been worse and so the incident was considered as a serious near miss. The site inspector visited B466 to review the actions taken following the incident and to discuss with REVISS operations staff the implications of the incident for them. It was considered that progress with the action plan deriving from the UKAEA investigation was satisfactory. Consideration is being given to engineered measures to improve safety in the facility, to avoid over-reliance on management arrangements. UKAEA has already stepped up its level of supervision of REVISS operations. NII welcomed the positive attitude shown by the operations staff interviewed.
UKAEA has started clearance of the chemical waste that was disposed of at the Western Storage Area. During this work incidents have occurred which have caused releases of chemicals to the atmosphere, both on and off the licensed site. The hazardous nature of the chemicals present in the WSA is well known and UKAEA has prepared and rehearsed emergency plans to deal with any accidental alert, plans which were activated successfully during the incidents. Workers close to the pits are protected by suitable protective equipment. Following the incidents UKAEA has reviewed its practices and implemented improvements. However the nature of the operations is such that similar incidents may occur in the future. NII has been assured that there is no radioactive hazard associated with the remediation of the WSA.
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 Approvals or Directions under conditions attached to the Site Licence were issued. The following Consents were issued:
Consent No 100. Assignment of a lease of B551 East and South wings to Scientifics Ltd, dated 22 April 2004.
Consent No 101. Assignment of a lease of part of B150 to HPL Imaging Centres Ltd, dated 22 April 2004.
Two Licence Instruments were issued:
Licence Instrument No 71, dated 22 April 2004, Site Licence No 44. Acknowledgement of receipt of a category B modification to the B462.23 Operational Safety Case for the receipt and storage of low enriched uranium fuel from Winfrith.
Licence Instrument No 72, dated 17 May 2004, Site Licence No 44. Acknowledgement of receipt of revised operational safety case for B459.
3The Ionising Radiations Regulations 1999 define the annual whole body dose limit for a radiation worker as 20 milli Sieverts, or 20,000 micro Sieverts.
Published on the HSE web site 8 October 2004