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 covers activities associated with the regulation of safety at Dounreay. These reports are distributed quarterly. Site Inspectors of HM Nuclear Installations Inspectorate attend the Dounreay Stakeholder Group meetings and will be happy to respond to any questions raised there. Any person wishing to inquire about matters covered in this report should contact the HSE, Nuclear Directorate Information Centre on 0151 - 951 - 4103.
This report will be put onto the HSE Website at http://www.hse.gov.uk/nuclear/index.htm
Site Inspectors and Specialist Inspectors visited Dounreay on the following dates:
11 – 14 and 24 – 28 January
15 - 16 and 21 – 25 February
14 – 18 and 21 – 22 March
These meetings are covered in appropriate sections of the report below.
NII activities during the period of this report covered inspection of compliance with Licence Conditions, monitoring of UKAEA investigations of incidents, review of the Life Cycle Base Line 2 and Near Term Work Plan 2, review of safety cases, and the issue of a number of licence instruments for operations and projects.
Routine Inspections
The planned routine inspection of the Dounreay site has been reduced this quarter due to the reduced manning level of the NII Dounreay site inspection team and NII’s involvement in DSRP/LCBL2 issues. This situation has been addressed with the transfer of a Site Inspector into the team in February; in addition, the site inspection team will be up to full strength on 1 April when a further Inspector joins the team.
A number of compliance inspections were carried out by the Site Inspectors; the issues raised are being followed-up as part of normal regulatory business.
Emergency Arrangements
A plant level emergency exercise carried out at DFR, involving a Sodium Potassium (NaK) fire, was inspected. Overall, the exercise was judged to be satisfactory and gave confidence that the DFR staff would be able to manage and recover from such a fire. However, contamination control and health physics monitoring at the Forward Control Point were identified as requiring improvement. UKAEA are to demonstrate improvements in these areas as part of the annual Level 1 emergency exercise to be held in May 2005.
Dounreay Site Restoration Plan (DSRP), Life Cycle Baseline 2 (LCBL2) and Near Term Work Plan 2 (NTWP2)
Along with representatives from other regulators and the NDA, a meeting was held to continue discussions on issues arising from the site’saccelerated decommissioning and restoration programme, as presented in LCBL2. The objective is to resolve the issues prior to submission of LCBL3 in June 2005.
NII participated in the NDA review of Dounreay’s Near Term Work Plan 2
(NTWP2). NTWP2 is the site’s detailed work plan for the next three years and is based on the longer term Life Cycle Base Line 2 (LCBL2) programme of work. A number of changes are being proposed to some of the activities and milestones presented in LCBL2. Some of these changes will require further discussion between NII, UKAEA and NDA. In addition, UKAEA are to provide more detail on the NTWP2 work activities to enable NDA to adequately administer the forthcoming contract and to demonstrate effective performance management. UKAEA has produced a NTWP2 Regulatory Schedule that identifies a set of milestones that are of interest to NII. The Schedule is to be further developed by UKAEA to incorporate comments provided by NII.
HSE –SEPA 1998 Audit Medium Term Recommendations
UKAEA has now submitted evidence to support close out of a total of 20 recommendations to NII. Currently, NII is reviewing these submissions to see if they are acceptable for closing out.
PFR Decommissioning
A meeting on the development of the Water Vapour Nitrogen (WVN) process for alkali metal residue removal was held at which UKAEA advised NII that aspects of this project were to be deferred. NII raised issues relating to the safety of the care and maintenance period of the reactor for an extended period of time and retention of skills in WVN/alkali metal technology. UKAEA are to consider means by which some progress could be maintained, particularly on the ongoing WVN development work.
DFR Decommissioning
Following the successful removal of the first 5 fuel element racks from the pond that demonstrated that doses are as low as reasonably practicable, NII agreed to the removal of the remaining 57 racks. Following success of the NaK crust sampling trial last year, NII has agreed that UKAEA can undertake work in the reactor vessel and primary circuit without further agreement from NII. The assessment of the safety documentation for the NaK disposal plant continues. A meeting was held with the intention of resolving as many as possible of the outstanding issues raised by NII.
Fuel Cycle Area
An inspection of D2670 and D1200 laboratories revealed a lack of clarity in the identification of Operating Rules and the need to improve some operating instructions. These issues are being taken forward with UKAEA.
An inspection of the fissile material store revealed that improvements are required in the current package storage arrangements in one of the rooms. UKAEA have agreed to take appropriate action to provide a better means of securing the packages to minimise the potential for dislodging.
An inspection of radioactive source management arrangements within the Fuel Cycle Area found them to be generally acceptable. Some specific areas for improvements were noted.
LLW Strategy
The strategy for the management of LLW has been agreed in principle with NII and SEPA although there are strategic decisions which need to be taken by NDA and Government. TheScottish Executive is still considering the authorisation for disposal of LLW from Dounreay to Drigg. NII is supportive of the output of the LLW BPEO to build a new disposal facility for Dounreay’s LLW, and in view of recent policy development and stakeholder consultation, is willing to discuss interim waste management arrangements with UKAEA. The management of High Volume/Low Active waste is currently important because of the lack of storage space on site and the proposed new disposal facility will not be available for some years.
Vulcan NRTE
16. NII carried out inspections at NRTE VULCAN during this quarter on the following dates:
1 – 5 February, and
21 March
Inspection topics covered during the above visits included:
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.
Improvement Notices
No improvement notices were issued on the Dounreay nuclear licensed site during the period of this report
Incidents on Site
No events have occurred during the quarter that met the Ministerial reporting criteria.
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.
HSE (Hazardous Installations inspectorate and NII) formally investigated the incident at Janetstown which occurred on 27th July 2004. The result of the investigation was the serving of two separate Improvement Notices on UKAEA and Alstec Ltd. A number of meetings have been held in the meantime and HSE is now satisfied that the subject of the Notices has been complied with. Overall, the improvements increase the rigour of the arrangements in the highly specialist technical area of alkali metal chemistry which is necessary for establishing safe systems of work for activities at Janetstown. At the time of the incident, HSE issued a ‘notice to leave undisturbed’ on the item of equipment in question (a tank containing sodium). After discussions with HSE, Alstec has now formally requested to be released from the notice and confirmed their proposals for continuing the work .
Pulsed Column Lab
The UKAEA investigation into the series of high nose blow samples recorded in the period August to November 2004, is now complete. NII has been closely monitoring the UKAEA investigation and is satisfied with the investigation and the recommendations which have led to improvements in the facility, including the ventilation system. It is believed that implementation of the recommendations should significantly reduce the likelihood of future problems. NII expects to be in a position to agree to the restart of decommissioning operations in early April and will closely monitor the work as part of routine site inspection activities. Following further biological monitoring, the maximum dose uptake was finalised at 2 mSv.
Shift Manning
UKAEA is planning to rationalise the shift chemist team. NII will be examining safety documentation for this change to ensure that safety arrangements are not adversely affected, and in addition, will conduct an inspection of the area during April 2005.
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:
A Licence Instrument to allow the replacement of the computerised nuclear materials accountancy system with a standard UKAEA-wide system has been issued.
Licence Instruments have been issued agreeing to the construction and inactive commissioning of an ILW waste drum repacking facility within D1203.
cc: NII File NIN 266/146 Pt 1 E4