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. NII activities during the period of this report covered:
Routine Inspections
3. A number of compliance inspections were carried out by the Site Inspectors and issues raised are being followed-up as part of normal regulatory business.
4. An incident involving the spillage of active liquor in the Dounreay Cementation Plant (DCP) has required the deferral of some routine inspection towards the very end of this quarter to allow the resourcing of an NII investigation.
Dounreay Site Restoration Plan, Life Cycle Base Line and Near Term Work Plan
5. NII continues to engage with UKAEA to satisfy itself that the impact of funding restrictions on the Dounreay Site Restoration Plan are minimised, and remain within bounds acceptable to the regulators.
6. In particular, NII continues to seek assurances from UKAEA that the immobilisation of PFR raffinates (which represent the most significant safety hazard on the Dounreay site) will not be delayed from the current agreed dates as a consequence of funding limitations.
7. NII understands that, due to budget constraints, UKAEA may seek to postpone some characterisation and modeling work intended to support contaminated land remediation on the site, in favour of specific work that may be required by SEPA.
8. NII is seeking further justification for some of the PFR decommissioning milestones in the Life Cycle Base Line/ Near Term Work Plan.
HSE –SEPA 1998 Audit Recommendations
9. Resource constraints have meant that there has been slippage in NIIs review of the submissions made by UKAEA as evidence to support close out of the medium term recommendations of this audit.
Organisational Change
10. A proposal to rationalise the Fuel Cycle Area shift team is currently being reviewed by NII and discussed with UKAEA. NII is yet to be convinced that some of the rationalisations proposed are adequately justified.
11. UKAEA continues to carry out a major review of safety, health and environment support at Dounreay, including support provided by the corporate centre. NII has informed UKAEA that it is likely to want to assess the adequacy of the safety submission for any significant organisational change affecting these functions.
Low Level Waste Storage
12. UKAEA intends to commence construction of an LLW interim store in November 2005 prior to expiry of planning permission in February 2006. NII may elect not to formally assess the proposal due to its relatively low hazard potential.
13. A recent inspection of Low Level Waste storage arrangements at Whatling’s Hanger identified the need for improvements in the monitoring of drum and ISO container condition during storage.
Rationalisation of Non Safety Related Maintenance
14. UKAEA are continuing to seek efficiency improvements in the scope and manner in which non-safety related maintenance is conducted, particularly in the Fuel Cycle Area. NII will continue to monitor this to be reassured that any such reductions in maintenance will not have an adverse effect on safety.
Incidents on Site
15. 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.
Dounreay Cementation Plant
19. Towards the end of this quarter, an incident occurred in DCP resulting in the spillage of a batch of MTR raffinate onto a cell floor. There were no injuries to workers and no radiological release has occurred from the cell itself.
20. Nonetheless, NII considers this to have been a significant incident and is conducting its own investigation to determine the circumstances and causes of the event, and to determine whether enforcement action is appropriate.
21. NII will also regulate recovery and restart activities to ensure that any radiation exposure to workers is as low as reasonably practicable.
Pulsed Column Lab
22. Pulsed Column Laboratory (PCL) staff have experienced a number of suspected personal contamination events over the last year. This has resulted in cessation of PCL operations on two separate occasions to allow UKAEA to investigate and implement necessary plant and procedural improvements.
23. A further event was reported during this quarter. However, UKAEA have since confirmed that this was due to cross contamination in an analytical laboratory, and that no workers actually received an exposure.
D9833 Silo
24. NII has written to UKAEA to ask for investigations to be completed to identify the source of traces of radioactive contamination and the origins of water level changes in an adjacent inspection manhole.
Operating Rules
25. NII has met with UKAEA to discuss NII inspection findings relating to the adequacy of conditions and limits necessary in the interests of safety (Operating Rules) arising from safety cases. UKAEA has accepted NIIs findings, and has undertaken to develop its internal guidance on Operating Rules further, and to provide NII with a forward programme of improvements.
Regulatory activity
26. 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:
27. NII has issued licence instruments: