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/nuclear under Local Liaison Committee ReportsNII inspectors visited Harwell on 8.5 days this quarter:
19 – 21 July Local Stakeholder Group Meeting
UKAEA reorganisation
LC 2 (Marking of the Site Boundary) inspection
Regulatory Forum Meeting
6 – 8 September Fire Certificate inspection
NII announced in September that, from 1 October 2005, Dr A T S Walker replaces Mr P S Watson as the NII Site Inspector for Harwell. Dr Walker has been involved with Harwell matters for the past two years, both in relation to the Site-Wide Periodic Safety Review and the consideration of UKAEA’s Life Cycle Baseline and Near Term Work Plan.
NII, the Environment Agency and UKAEA continued the practice of meeting 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 and Near Term Work Plan. This matter is reported separately below.
The site inspector carried out an inspection of arrangements made by the licensee under LC2 and a sample inspection of the licensed site boundary. The LC2 arrangements were considered to be generally adequate and the management of maintenance was satisfactory. The condition of the site fence was satisfactory, however there was no signage along part of the fenceline. Hence UKAEA were asked to make improvements, and they have confirmed the steps to be taken to improve compliance with LC2, and this is considered to be satisfactory.
In August 2005 The Health and Safety Executive published its criterion for delicensing parts of, or entire sites licensed under the Nuclear Installations Act 1965. The policy statement, ‘HSE Criterion for Delicensing Nuclear Sites’ forms the basis from which HSE can establish, from its own assessment, the licensee’s evidence and information from other regulators, that any residual radioactivity on a nuclear site, additional to the natural background, represents ‘no danger’. Once the licensee demonstrates it can meet HSE’s ‘no danger’ criterion, HSE will be able to make a decision on delicensing all or part of the site. Currently, HSE is considering an application from UKAEA to delicence part of the Harwell site.
The requirement for licensees to demonstrate ‘no danger’ is a legal duty imposed by the Nuclear Installations Act 1965. HSE believes the most helpful way to define ‘no danger’ is to present it in terms of an assessed numerical risk to human life, rather than simply using a vague phrase such as “very low risk”.
In summary, HSE’s requirement for establishing ‘no danger’ when considering a delicensing application is “A demonstration that any residual radioactivity, above background radioactivity, which remains on the site, which may or may not have arisen from licensable activities, will lead to a risk of death to an individual using the site for any reasonably foreseeable purpose, of no greater than one in a million per year”.
The policy statement, 'HSE Criterion for Delicensing Nuclear Sites', (available in English and Welsh) can be accessed on HSE’s website at: HSE criterion for delicensing nuclear sites [PDF 65kb].
UKAEA explained the proposed organisational changes in anticipation of site management competition required by the Nuclear Decommissioning Authority. The proposals had been endorsed by the Shareholder Executive acting on behalf of the Depatment for Trade and Industry. NII considers that the proposed organisational changes could have a major effect on safety of UKAEA operations. As a result it is likely that NII will assess the safety submission UKAEA is required to make under Licence Condition 36. At the end of September UKAEA organised a workshop to provide relevant NII inspectors with a chance to understand and provide early feedback on the proposals.
NII, in conjunction with its colleagues in the Environment Agency and the Office for Civil Nuclear Security, has continued to support the work of the Nuclear Decommissioning Authority during quadra-partite meetings with UKAEA concerning UKAEA's proposed Life Cycle Baseline for the site. An early draft baseline has been reviewed and is now undergoing final detailing in preparation for an NDA final review that will be held in October. UKAEA has also completed the drafting of an Integrated Waste Strategy (IWS) for the site, which outlines how all the different legacy wastes on the site are to be processed and managed. The IWS is currently undergoing due process within UKAEA ahead of its issue and it will continue to be underpinned by the LCBL into the future. NII has has taken a keen interest in the production of the IWS and welcome its completion as being a key step in validating the work scope and timescales declared of the LCBL.
A further inspection for compliance with the Fire Certificate was carried out by the HSE Fire Surveyor and the Site Inspector. It was concluded that UKAEA has not acted quickly enough on health and safety requirements previously raised by HSE. It was agreed that UKAEA should prepare an action plan without delay. HSE advised that the failure to respond to these actions in a timely manner would result in the serving of an enforcement notice under the Fire Certificates (Special Premises) Regulations 1976.
A potentially significant issue arose concerning the evacuation of the Radiochemical Laboratories (and probably other facilities at Harwell) in the event of a fire. The fire evacuation procedure has been detailed so that when personnel hear the fire alarm signal they are to proceed to the assembly area situated in the conference room at first floor level of the main building. This is contrary to the standard evacuation procedure for buildings. The resolution of this matter will be discussed further with UKAEA.
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, one Licence Instrument was issued:
LI No 510. Agreement to the licensee proceeding with the Category B modification as described in Safety Justification for the Extension of the Harwell Package Movement Safety Cases, referenced TSWP(03)P359, Issue 2, dated 2 March 2004,