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
1. Site Inspectors and Specialist Inspectors visited Dounreay on the following dates:
2. Mrs Margaret Burns, Health and Safety Commissioner, visited the site to gain information on ongoing and planned site decommissioning and restoration activities. A number of presentations were given by UKAEA and visits were made to a selection of facilities across the site.
3. Members of NII’s Inspection Coordinating Group (ICG) visited the site. Presentations were provided by UKAEA on progress on site decommissioning, future strategy, programme and challenges, shaft and silo waste retrieval, and new build projects. Plant visits were made to the reactors, shaft and silo, and a number of plants in the Fuel Cycle Area.
4. NII activities during the period of this report covered inspection of compliance with licence conditions, a team inspection of training and competency arrangements, observation of the annual demonstration emergency exercise, monitoring of UKAEA investigations of incidents, review of the Dounreay Site Restoration Plan and Life Cycle Base Line, review of safety cases, and the issue of a number of licence instruments for operations and projects.
5. Routine Inspections
Inspection of the Dounreay site has continued largely as planned during the quarter. A number of compliance inspections were carried out by the Site Inspectors and the issues raised are being followed-up as part of normal regulatory business.
Emergency Arrangements
6. The Dounreay annual demonstration emergency exercise was held on
18 May 2004. The exercise scenario was based around an incident involving a failed lift of a container at the Prototype Fast reactor (PFR). The incident resulted in a breach of containment, sodium fire, release and spread of activity and sodium combustion products around PFR, onsite, and offsite, and multiple casualties.
The exercise tested the site arrangements for setting up the various incident control centres, mustering of personnel, recovery and treatment of casualties, establishing local containment of the leak, and producing a viable recovery plan. Overall NII judged the exercise to be a satisfactory demonstration of UKAEA Dounreay's emergency arrangements. The key lesson to be learned relates improvements to be made to command and control techniques at the Forward Control Point.
Dounreay Site Restoration Plan, Life Cycle Base Line and Near Term Work Plan
7. A formal review of progress against the Dounreay Site Restoration Plan (DSRP) and Life Cycle Base Line (LCBL) 2004/05 was held. Overall, progress on the DSRP and LCBL 2004/05 was considered satisfactory. A number of change proposals from LCBL 2004/05 and Near Term Work Plan (NTWP) 2005 remain to be agreed. Discussions with UKAEA, aimed at reaching agreement on these outstanding change proposals are ongoing.
8. UKAEA presented their current proposals on the development of the 2005/06 LCBL which is based on the application of their prioritisation procedure. UKAEA advised there would be no further delays to high priority milestones, minimal delay to medium priority milestones and delays of up to 10 years on low priority milestones. A more detailed review of some of these change proposals will be carried out by NII.
9. HSE –SEPA 1998 Audit Recommendations
UKAEA has now submitted evidence to support close out of 24 of the 27 medium term recommendations to NII. To date, 7 of these recommendations have been closed out by NII. NII is currently reviewing the remaining submissions to determine if they are acceptable for closing out. In addition, UKAEA has produced a programme for close out of the 27 long term recommendations; the programme shows completion of submissions to NII in January 2006.
Organisational Change
10. NII has reviewed and has no objections to UKAEA’s proposals to rationalise the shift chemist team and for initial emergency response during silent hours. Nonetheless, NII will continue to monitor the effect of these changes over time. A proposal to rationalise the Fuel Cycle Area shift team is currently being reviewed by NII and discussed with UKAEA.
11. UKAEA are carrying out a major review of safety, health and environment support at Dounreay, including support provided by the corporate centre.
Options being considered include a reorganisation into assurance functions and service functions with a much reduced corporate support role. Once the review is complete, a change proposal will be submitted by UKAEA to NII for assessment and agreement.
Team Inspection of Training and Competency
12. NII carried out a team inspection of licence condition arrangements for training and competency. Overall, the site’s arrangements were considered to be acceptable, with a number of good practices noted. UKAEA is in the process of implementing new arrangements for managing competence across all its nuclear licensed sites. The inspection identified a number of areas for improvement that UKAEA are currently addressing. Progress on implementing these improvements will be monitored as part of normal regulatory business.
Prototype Fast Reactor Decommissioning
13. As a result of funding constraints, UKAEA proposed deferral of the Prototype Fast Reactor (PFR) alkali metal residue removal project. NII expressed concern at this and as a result, UKAEA developed a revised strategy for the project that satisfies NII’s concerns. The new plan is to destroy the sodium residue by the Water Vapour Nitrogen process but operating at a low concentration of water vapour/nitrogen over a longer timescale. This revised operating regime will require further development but is expected to overcome the problem of pressure excursions. NII will be closely monitoring the development of this project.
Dounreay Fast Reactor Decommissioning
14. Discussions have been held with Dounreay Fast Reactor (DFR) staff to agree appropriate Personal Protective Equipment (PPE) to be worn in the DFR sphere in the event of emergencies. It was agreed that UKAEA could provide oxygen generating smoke hoods for use when NaK transfer operations are being carried out. This still needs to be agreed with the HSE Fire Surveyor.
15. A number of safety cases for DFR projects are currently being assessed by NII. Several outstanding technical issues from assessment of the NaK Disposal Plant construction and commissioning safety case remain to be resolved before NII can agree to the commencement of inactive commissioning of the plant. The Preliminary Safety Report (PSR) for the Goliath crane upgrade has been submitted by UKAEA and is currently being assessed by NII. The Pre Construction Safety Report (PCSR) for the Breeder Fuel Removal project has been submitted and is undergoing assessment by NII. It has been agreed with UKAEA that NII agreement for construction will be phased. The first phase will cover construction of a new external processing facility, whilst the second phase will cover commencement of the more hazardous in-sphere work.
16. Following a series of compliance inspections in the Fuel Cycle Area (FCA), evidence was found that some Operating Rules are being defined at too low a level or reiterating licence condition and radiation protection requirements. This is considered to be a generic problem possibly associated with the nature of UKAEA corporate guidance relating to Operating Rules. A meeting with UKAEA has been arranged with the objectives of achieving a common understanding of the underlying issues, and agreeing a means of carrying this issue forward.
17. The Scottish Executive directed the Scottish Environment Protection Agency (SEPA) to refuse UKAEA’s application to dispose of solid Low Level Waste (LLW) to Drigg. This decision will necessitate storage of LLW at Dounreay as an interim measure until a disposal route is finalised. Consequently, UKAEA intend to proceed with the construction of an interim LLW store. In the longer term, UKAEA propose to build a new disposal facility at Dounreay for the site’s LLW. NII is supportive of this proposal and considers that this project should be implemented with appropriate priority.
Contaminated Land
18. A meeting was attended along with representatives from Scottish Environment Protection Agency (SEPA), Highland Council and UKAEA to discuss issues relating to contaminated land on the Dounreay site. As a result of a recent EC Directive, there is a potential requirement that groundwater be remediated to drinking water standards. NII is concerned that such a requirement may detract from decommissioning more hazardous facilities.
Incidents on Site
19. No events have occurred during the quarter that met the Ministerial reporting criteria, and no improvement notices were issued during the period of this report. NII gives updates to the Dounreay Stakeholder Group on progress of any significant recommendations from either their own or UKAEA’s investigations. In addition, UKAEA has a database of incidents and their progress with close out of recommendations is inspected regularly by NII.
Pulsed Column Lab
20. Following a shut down period consequent to a series of personal contamination events, sufficient improvements were made such that UKAEA were able to restart operations. Following a period with no further incidence of personal contamination, a number of routine nose blow samples showed elevated levels of radioactivity. Operations were again stopped. An investigation conducted by UKAEA established that, in these cases, the cause was most likely to be associated with cross contamination in the analytical laboratories that analysed the nose blow samples, rather than with actual intakes by the workers involved. Bioassay samples provided by the workers involved indicated no measurable intake of radioactive materials. As a consequence, NII has agreed to the recommencement of operations in the facility.
Regulatory activity
21. 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:
22. A Licence Instrument has been issued agreeing to the commencement of Phase C of DFR pond decommissioning.
23. Licence Instruments have been issued agreeing to the active commissioning and operation of an ILW waste drum repacking facility within D1203.
24. A Licence Instrument has been issued acknowledging receipt of the Preliminary Safety Report for the D3900 intermediate level waste immobilisation, encapsulation and storage facility, and notifying UKAEA of NII’s intent to examine the pre construction safety report and that constuction should not proceed without agreement from NII.
25. A Licence Instrument has been issued agreeing to the construction of the DFR NaK Disposal Plant.
cc: NII File NIN 266/146 Pt 1 E8