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 sites available to the public. It is for distribution to members of the AWE Local Liaison Committee (LLC) and covers activities associated with the regulation of safety at Aldermaston and Burghfield. These reports are distributed quarterly and are available also from the Internet at http://www.hse.gov.uk/nuclear/index.htm. Site Inspectors of HM Nuclear Installations Inspectorate attend LLC meetings and will be happy to respond to any questions raised there by members. Any other person wishing to enquire about matters covered by this report may contact HSE’s Nuclear Directorate on 0151-951-3484/3290.
A total of 26 NII inspectors visited the Aldermaston and Burghfield sites during the quarter. In addition there was a visit to AWE Blacknest and there were visits from other HSE inspectors in relation to conventional safety, and explosives. NII inspections were made on the following dates:
Inspections are undertaken for the purpose of monitoring compliance with (i) the conditions attached by HSE to the nuclear site licences, and (ii) other relevant provisions of the Health and Safety at Work etc Act 1974, including the Ionising Radiations Regulations 1999. In this period routine inspections included:
The site inspection team held a meeting with AWE’s new director of assurance. The major issues discussed were the assurance resources in the areas of: independent review, internal regulation, and corporate arrangements. The director’s view was that he has sufficient resources and was intending to redeploy some of these to improve effectiveness.
Meetings have been held to discuss AWE’s progress towards developing a corporate framework for managing their training and competence needs. The proposed framework appears soundly-based, and should provide a systematic approach to determining and delivering the company’s competence needs. Issues of data access and contractor competence data are being raised with AWE.
In the area of organisational baseline AWE wishes to restrict this to only include those who could affect nuclear safety. Although this approach has attractions, not least the improved manageability of the Baseline, it does not provide a means of demonstrating that the licensee knows how many staff are needed to carry out front end operations, and therefore that sufficient personnel are in place. Discussions on AWE’s approach continue.
NII is supporting AWE in the development of improved co-ordinated arrangements for the delivery of major projects. Progress is being made in developing a project delivery organisation, establishing a process to enable the licensee to remain the intelligent customer, ensuring personnel are demonstrably suitably qualified and experienced (SQEP) and producing a management system for project delivery. Inspections have been planned to test the adequacy and level of implementation of AWE's project related arrangements.
The annual major meeting between the regulators and safety representatives was held. The regulators represented included FOD (Field Operations Directorate), HID (Hazardous Industries Directorate) and NWR (Nuclear Weapons Regulator) as well as NII. Key issues raised by the safety reps were: increases in radiation doses (though still well within limits) to some workers in decommissioning facilities; authorisation issues with work carried out by contractors in a decommissioning facility; and, possible confined spaces issues with a new fire suppression system. These issues are being followed up.
NII is disappointed with the progress in respect of the recommendations arising from the Review Learn and Improve inspection carried out a year ago. NII has asked AWE to give this more priority.
NII has agreed that AWE has met the requirements of Licence Instrument, LI 48 (which required the reclassification of 130 drums of ILW as LLW (low level waste)). However, LI 49 requires a certain amount of material to be put through an ILW treatment plant by end 2006. Due to the lack of a treatment plant AWE will not now be able to achieve this and has sought early renegotiation of this LI. AWE has now also accepted the need to move towards a supercompacting facility, and further discussions are ongoing concerning grouting (i.e. to secure passive safety).
Meetings with AWE took place to discuss an integrated waste strategy, progress with their QQR (Quinquennial Review, waste treatment plant closeout matters and ILW (Intermediate Level Waste) treatment plant. NII asked AWE to substantiate the case for unattended out of hours operation of the WTP (Waste Treatment Plant), due to start operations early March. An initial assessment of AWE’s case shows that doses from all potential leaks are very low. Nonetheless, AWE are being asked to confirm that timely action will be taken to seal any leaks identified out of hours.
The AWE project team gave NII a presentation on further progress in the periodic safety case area. This work continues to be on schedule for delivery to NII in Dec 2006. AWE has been working with the NII Assessors and Inspectors to ensure that the approach applied to the revision of Safety Cases is clear, well understood and of an agreed standard. This will be confirmed by NII assessment of the Periodic Review of Safety (PRS).
NII has issued a Licence Instrument (Agreement) for the commissioning work on a material test facility to proceed beyond hold point 2, inactive commissioning.
A total process summary report for the criticality fault trees and probabilistic safety assessment has been submitted by AWE for the main production facility. The report includes a list of the outstanding recommendations, and the overall impact on the risk. All recommendations requiring immediate attention to achieve acceptably low risk operations have been completed. Other lower priority recommendations are to be pursued as part of an ALARP (As Low As Reasonably Practicable) programme under the periodic safety report work.
New facilities offer safety gains from reduction of risks compared to facilities designed to older standards. NII is pursuing the early construction and use of new assembly/ disassembly facilities at Burghfield, in order that work associated with the current AWE programme is predominantly carried out in the new facilities. Recently delays have occurred in the design phase, which may result in extended use of the current facilities. NII has advised AWE that a consequence of extended use of existing facilities will be that the periodic safety report may need to contain more demanding justifications and additional engineering.
AWE has identified the work programmes associated with the Burghfield PRS. However, the detailed work packages are still awaited. NII will use these to judge the adequacy of remedial measures, and is concerned about the timing of submissions. The main PRS improvement work is to be completed by September 2007.
The NII has undertaken observations of the dis-assembly of certain weapons components although time constraints did not allow the whole process to be viewed. Video evidence is to be used to conclude these observations.
1. Licence Instruments are issued to acknowledge receipt of specified documents, e.g. proposals for a new or modified plant; to stipulate whether the Inspectorate intends to examine these documents, or to agree to the start of a particular phase of construction, commissioning, modification, or decommissioning.