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 26 days this quarter:
8 April Local Stakeholder Group meeting
11 – 14 April Training and competence enhanced inspection
19 – 20 April Fire Certificate inspection
27 April Regulatory Forum meeting
5 May Visit by HM Chief Inspector of Nuclear Installations
11 – 12 May Emergency exercise Review Meeting
LCBL 2005/06 Preliminary Review
Waste Encapsulation Plant
24 – 25 May Fire Certificate inspection
22 – 23 June NDA Interim Review of LCBL 2005/06NII, the Environment Agency 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.
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 2005/06, regulation of activities undertaken by REVISS Services UK in B466, and the Waste Encapsulation Plant. These matters are reported separately below.
A team of four NII inspectors carried out a planned inspection for compliance with Licence Conditions (1) associate with training and competence. This was the first of a series of inspections to be carried out on all four of the UKAEA nuclear licensed sites, with the objective of comparing site and benchmarking practices. As an aid to industry benchmarking, NII’s team included a Sellafield site inspector.
There were several examples of good practice and no issues of major non-compliance at Harwell, though there were areas where improvement is required. NII noted that UKAEA has recently implemented a new management system for training and competence that will take time to become fully established. NII is finalising a report covering all four inspections, and the outcome of the work is expected to be sent to UKAEA in July 2005 which will be covered in the next report to the LSG.
The Site Inspector met UKAEA staff to review the emergency exercise improvements since the previous Level 1 (2) exercise, and to look forward to the next exercise in October 2005. Progress with actions arising was considered satisfactory.
Dr Mike Weightman visited Harwell on 5 May. He was impressed by the positive attitude and enthusiasm of all staff met. He enjoyed the opportunity of talking to Safety Representatives, and stated that HSE very much values the work that they do to enhance health and safety standards at Harwell.
We discussed the need for continuity through the changes that are occurring due to the formation of the Nuclear Decommissioning Authority (NDA) and its contractual role with UKAEA. Dr Weightman emphasised that the licensee remains fully in control of their operations at all times. The licensees retain 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. As always, criminal law takes precedence over civil contracts in the event of any conflict between the two.
NII commented on the varying standards of conventional safety observed during the visit. UKAEA was asked to review standards of personal protective equipment across the Harwell site and convey the findings to the NII Site Inspector. Since the visit, NII has learned that r eviews of specific operations are being carried out and new arrangements are being put in place for the supply of PPE. This will consist of a distribution point on site stocked by an external supplier. This will increase the range of available PPE on site. The arrangements for identification, supply and control have PPE have been discussed in detail with Safety Representatives
NII participated in this Review, which was made up of presentations by UKAEA according to a standard agenda set by NDA and discussions across the topics. The changes from the previous LCBL were not significant. The key emerging issue related to the strategy for storing and disposing of intermediate level waste (ILW). One of UKAEA's principal assumptions is that an off-site route for all ILW with the necessary authorisations will be available from 2015. But NII recognises that such decisions need to be taken at a national level, and NII looks to NDA to work with other parts of Government to develop an acceptable strategy for radwaste .
These Fire Certificate inspections were the latest in a series conducted by the HSE Fire Surveyor, dating back to March 2004 at a time when he took over Fire Certificate inspection responsibilities for Harwell. The inspections did not give rise to any major issues. The level of progress by UKAEA in dealing with Fire Certificate issues is slower than would be expected, due to resourcing difficulties that are partly out of UKAEA’s hands. NII sensed a willingness to listen and make improvements, and it is expected that progress will improve once a dedicated specialist fire officer is appointed.
The site inspector participated in a meeting with UKAEA, the Environment Agency and REVISS Services UK (the tenant in B466, which is used for the receipt, storage and export of radioactive sealed sources). The purpose of the meeting was to discuss and resolve issues related to the regulation of activities by NII and the Agency of activities in B466. We agreed that:
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 no Licence Instruments were issued.
1. Licence Conditions 10 [Training], 12 [Duly Authorised and other Suitably Qualified and Experienced Persons] and 26 [Control and Supervision of Operations].
2. Level 1 emergency exercises comprise a physical demonstration of the licensee’s emergency arrangements on site against a pre-determined (but confidential) scenario.