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 Chilton Campus Local Stakeholder Group (LSG) 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 LSG meetings and will be happy to respond to questions raised there by members of the LSG. Any other person wishing to inquire about matters covered by this report should contact the HSE, Nuclear Directorate Information Centre on 0151-951-4103.
This report will be put onto the HSE web site, at www.hse.gov.uk/nsd/nsdhome under Local Liaison Committee ReportsNII inspectors visited Harwell on 27 days this quarter:
11 – 13 January Regulatory Forum (UKAEA, NDA and regulators)
Delicensing
B466 inspection
19 January B462 shielding inspection
1 – 2 February Site visit by NII Unit Heads
8 February Initial NDA review of Harwell Near Term Work Plan
8 – 11 February Inspection for compliance with Ionising Radiations Regulations 1999
22 – 24 February Regulatory Forum
Management of Radioactive Materials Transport
Annual Review Meeting
8 – 9 March Interim NDA review of Harwell Near Term Work Plan
LETP unannounced inspection
Flask embargo
23 March Final NDA review of Harwell Near Term Work Plan
Visit to Winfrith and Harwell by Heads of NII Assessment Units
The heads of the two units in NII responsible for technical assessment of UKAEA safety cases carried out brief familiarisation visits to Winfrith and Harwell, accompanied by the site inspector. The purpose of the visits was to provide an opportunity to better understand the likely demands on the assessment. Overall the visits proved to be most useful. UKAEA’s organisation of the visits was good, and the response of their staff was positive and helpful. NII welcomed the progress with decommissioning at both sites, and commented that generally housekeeping standards were good.
Monthly remote contact meetings
NII and UKAEA continued the practice of meeting remotely (by videoconference) on a monthly basis. These meetings are not a substitute for regular site inspection visits, but they help maintain close contact whilst reducing travel time and costs and are seen by all parties as effective. Recently EA has started participated in the monthly meetings which further adds to their value.
Liaison with Other Government Department
Key issues continue to be discussed with the Environment Agency. Included this quarter was a Regulatory Forum meeting for consideration of UKAEA’s Life Cycle Baseline and Near Term Work Plan for Harwell, matters which are reported separately below.
Harwell Annual Review meeting, 23 February.
NII participated in the Harwell Annual Review of Safety Meeting. This included a review across all of the main aspects of site operations, including the work of tenants occupying Cat 1 and 2 facilities. This meeting was well organised with advance papers to a high standard and on time, and with positive contributions from all participants including tenants and safety representatives. The meeting showed that UKAEA’s (and their tenants’) general safety performance over the year has been generally satisfactory, and confidence was gained regarding UKAEA’s future performance.
Licence Condition (LC) Compliance inspections
Maintenance inspection close-out meeting, 28 January.
The site inspector attended a meeting with UKAEA to close out the inspections at Harwell, Windscale and Winfrith in November 2004 and discuss NII’s report. Generally UKAEA supported the conclusions and recommendations arising from this inspection, and some amendments to the report were agreed.
Harwell Lifecycle Baseline (LCBL) and Near Term Work Plan (NTWP)
NII wrote to UKAEA to confirm our views on Harwell’s second LCBL. We acknowledged that LCBL2 is a significant improvement on LCBL1, and recognised that this has been a challenging task for the site. However, NII remains to be fully convinced that UKAEA’s proposals adequately address our nuclear safety regulatory interests. We expect these issues to be addressed in LCBL3. Our primary concerns can be summarised as the absence of a transparent underlying radioactive waste and decommissioning strategy; the reliance upon an as yet unknown site to provide the route off the site for much of the decommissioning ILW; and the inclusion of waste ‘hand-offs’ to other sites without secure agreements with these sites regarding timescales, programmes and service levels.
Harwell’s NTWP for 2005 was received only a week before the Nuclear Decommissioning Authority (NDA) Formal Review on 23 March. Given the considerable size of this document, NII considered that the time available to review this document was inadequate. However, NII also attended informal reviews of the NTWP2 in February and March which provided an opportunity to discuss some of the content of NTWP2 in advance of its submission. NII also participated in the 23 March Formal Review.
A key element of NTWP2 is the Regulatory Schedule, which is a programme of site activities requiring regulatory input or action. As yet the Regulatory Schedule is at an early stage in its development, but it will become a useful tool for assisting the interface between UKAEA and the regulators.
The contract between UKAEA and the Nuclear Decommissioning Authority was signed on 1 April 2005. UKAEA retains absolute financial liability for any harm resulting from incidents on their sites and their responsibilities for management of nuclear safety and operational decisions must not be diluted or appropriated by others. NII will continue to inspect for compliance with health and safety law, which is criminal law. As always, criminal law takes precedence over civil contracts in the event of any conflict between the two.
IRRs inspection, 8 – 11 February 2005.
The site inspector and NII assessment inspectors carried out an inspection for compliance with the Ionising Radiations Regulations 1999. The focus was facilities which undertake operations which are believed to be non-licensable, though we also visited B462 to benchmark against a UKAEA facility. Generally compliance with IRRs was satisfactory. There was a number of examples of good practice, and some issues which UKAEA and tenants will need to follow up though nothing of major significance.
Delicensing
On 13 January, NII met with UKAEA Harwell and Winfrith, together with EA and NRPB, to discuss the two current delicensing applications and learn of progress with future applications. (NRPB is contracted to NII to provide independent monitoring surveys of land scheduled for delicensing.) Both applications are on hold pending the confirmation of HSE’s revised decommissioning strategy. The revised HSE Policy Statement is due to be confirmed in August 2005, and internal guidance on the interpretation of the delicensing criteria should be with licensees by summer 2005.
Licensability of REVISS’ operations in B466
NII completed a review of the licensability, under the Nuclear Installations Act 1965 (as amended), of operations carried out in B466 by REVISS, a tenant of UKAEA.
B466 was constructed in 1957 as the cooling pond for irradiated fuel from the materials test reactors at Harwell. The last stored fuel was removed in 1990. Since 1994 B466 has been used exclusively for the receipt, unload, reconfiguration and storage of irradiated sealed cobalt and caesium sources and other material prior to dispatch to facilities on or off the Harwell site.
NII concludes that B466 itself is licensable, because of its previous use, but that REVISS’ current operations within B466 are probably not licensable. This decision may have to be revisited if in future REVISS wishes to change the operations being carried out in B466. B466 remains as a Category 1 facility and hence the safety management arrangements and plant procedures must comply with UKAEA requirements for Category 1 facilities.
NII also stated that REVISS could carry out the same operations within an appropriate facility on a non-licensed site, subject to the requirements of planning, environmental and any other regulatory requirements. For this reason HSE radiation protection specialists and the Environment Agency have been advised of NII’s decision, having been consulted extensively during our deliberations.
Graviner flask embargo
Discussions were held with UKAEA and a way forward agreed to enable the partial relaxing of restrictions currently in force on the use of Graviner flasks in B462.26. This will enable UKAEA to continue to recover waste cans of a defined activity level.
Liquid Effluent Treatment Plant unannounced inspection
An unannounced inspection of the Liquid Effluent Treatment Plant (LETP) was carried out in March 2005. It was considered that there is adequate control over the receipt, treatment and discharge of liquid effluent. There has been some progress with managing radwaste accumulations, but problems still exist and UKAEA was advised that, without delay, it should ensure that waste is properly disposed of and the facility managed to prevent accumulations.
The overriding impression was one of a facility close to the end of its operational life. NII supports UKAEA’s intention to withdraw from the LETP progressively but as soon as reasonably practicable.
Divestment of AEAT Waste Management Technology Limited
Further discussions with UKAEA and AEA Technology plc continued on the proposed divestment of AEAT’s Waste Management Technology Limited. AEAT announced change to the scope of the divestment: none of the Harwell facilities operated by AEAT will now feature in the divestment.
NII has powers under the Nuclear Site Licence Number 44 to issue Consents, Approvals and Directions. In addition, NII can issue Notifications, Specifications, Acknowledgements and Agreements under the conditions attached to the Licence, or under arrangements made by UKAEA for complying with those conditions.
A new numbering system was introduced on 1 October 2004 for site licence actions, and all such actions are now called Licence Instruments.
During the quarter the following Licence Instruments were issued:
LI No 506. Consent. Grant of lease of part B404.13 to Oxford Drying Service Limited. 1 February 2005.
LI No 507. Acknowledgement and Specification. Preliminary Safety Report for the Harwell B462.9 Retrieval Machine. 1 March 2005.