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 17.5 days this quarter:
7 - 8 July
Site-Wide Periodic Safety Review close-out meeting
Flask safety case
13 - 14 July
HMNII Chief Inspector's visit to Harwell
22 - 23 July
Flask safety case
LLC Meeting
1 - 3 September
Regulatory Forum
REPPIR compliance
Unannounced inspections
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 nuclear regulatory issues continue to be discussed with the Environment Agency. Included this quarter was the second Regulatory Forum meeting for consideration of UKAEA's Life Cycle Baseline 2 for Harwell: this matter is reported separately below.
Harwell unannounced compliance inspections
The site inspector carried out unannounced compliance inspections in B459 and B466. Control and supervision were adequate. Concerns were raised on LLW accumulations in B459.6 which are being actioned. Although B466 pond integrity does not appear to be a major issue, UKAEA was asked to provide further assurance on its ability to identify potential leakage from the pond
HMNII's Chief Inspector, Laurence Williams, visited Harwell. He met key staff including Safety Representatives and Trade Union representatives. This was a well organised and productive visit. Mr Williams was encouraged by the progress with decommissioning across the site, welcomed the positive attitude and enthusiasm of all staff we met. Mr Williams enjoyed the opportunity of talking to Safety Representatives and Trade Union representatives and reiterated that NII very much values the work that they do to enhance health and safety standards at Harwell.
The Nuclear Installations Act 1965 (as amended) allows delicensing if 'no danger' can be demonstrated, but does not define what this means. HSE has set up public consultation on the meaning of 'no danger'. As yet the results of this consultation are still being considered, but on completion HSE is expected to publish its policy. NII currently has one delicensing application in respect of Harwell, and NII will continue to encourage to progressive delicensing of Harwell where 'no danger' can be demonstrated.
UKAEA has confirmed that the Harwell Emergency Response Team (operated by Scion as contractor to UKAEA) has voted for industrial action, in response to a long-running local dispute. Safety arrangements, in the absence of the Emergency Response Team, have been reviewed by UKAEA for all facilities on the licensed site. NII is satisfied that UKAEA has adequate contingency plans in place for maintaining safety on the Harwell site during industrial action.
An inspection was undertaken for compliance with the Radiation (Emergency Preparedness and Public Information) Regulations 2001, referred to as REPPIR. The inspection confirmed that Harwell is satisfactorily compliant with REPPIR. Some comments were raised which will be progressed through routine inspections.
NII participated in the second Regulatory Forum meeting (comprising representatives from UKAEA, Liabilities Management Unit and the regulatory bodies) to discuss the draft second version of Harwell's Life Cycle Baseline document, referred to as LCBL2. NII commented that we had not yet seen an overarching site strategy for radwaste management to substantiate the logic expressed in LCBL2. However NII was pleased to note that UKAEA's plans included the clearance of waste disposed of in the Meashill plantation and trenches.
Divestment of AEAT Waste Management Technology Department
NII completed its consideration of UKAEA's proposals for controlling the divestment of AEAT's Waste Management Technology Department (WMTD) at Winfrith and Harwell. AEAT, as tenant of UKAEA, operates at Harwell a depleted uranium store and a facility for maintaining packages for the transport of radioactive material. A letter has been sent to UKAEA confirming that Licence Condition 3 (Restriction on dealing with the site) applies to the divestment and formal Consent will be required, but that NII broadly accepts the proposals as an acceptable way forward for divestment of WMTD. NII now seeks UKAEA's detailed strategy for managing the divestment.
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. NII is working with UKAEA to arrive at a satisfactory safety case to enable the embargo to be lifted, and a partial relaxation of the embargo - for the recovery of waste with a low radioactive inventory - was agreed in August 2004.
NII has powers under the Nuclear Site Licence Number 44 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 102. Grant of lease of B413 (East) to I.C.E. Facilities Management Ltd, 7 July 2004
Consent No 103. Assignment of a lease of B404 to ISS Facility Services Ltd, 24 September 2004
Consent No 104, Grant of lease of B401.4 to Thames Valley Police Authority, 13 July 2004
Licence Instrument No 73, Acknowledgement of receipt of the Operational Safety Case for HELIOS-1 Linear Accelerator, 20 July 2004
Licence Instrument No 74, Acknowledgement and Notification of Intention to Examine the Pre-Operational Safety Report for the B462.27 Intermediate Level Solid Waste Store, 10 September 2004
Licence Instrument No 75, Acknowledgement and Notification of Intention to Examine the Pre-Operational Safety Report for Waste Retrieval Operations in B462.2 and B462.9, 10 September 2004
Licence Instrument No 76, Acknowledgement and Notification of Intention to Examine the Safety Justification for the Extension of the Harwell Package Movement Safety Cases, 10 September 2004
Published on the HSE web site 03 January 2004