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 and are also available on the HSE’s web site at http://www.hse.gov.uk/nuclear/llc/2006/index.htm. 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 on 0151-951-3484/3290.
[back to top]The Site Inspector made three planned visits to Harwell during the quarter. His inspections and discussions covered a number of regulatory topics including safety cases, operating limits and conditions, low level waste management, and the Life Time Plan for the site. He was joined by a specialist inspector for discussions with UKAEA on delicensing the North Gate Area of the site. He also accompanied a specialist inspector from HSE’s Field Operations Directorate who undertook an overview inspection of UKAEA’s compliance with conventional safety regulations and requirements. Further information on matters of interest is provided in the following sections of this report.
[back to top]As indicated in above, these covered licence condition compliance matters and other relevant safety related aspects of operations, maintenance and both technical and safety support. For the most part, the inspections and discussions during the quarter revealed nothing of concern and compliance was judged to be adequate.
In the case of operating limits and conditions relating to the movement of one of the shielded flasks used to move radioactive materials across the site, UKAEA was able to demonstrate that the requirements that were set out in various safety case documents were properly reflected in the current operational documentation under which the flask is prepared for service, loaded and then moved. The position regarding the safety case documentation was complicated by the fact that the original safety case has been extended to include considerations relevant to modern standards, rather than being completely revised to do so. While this is in accordance with UKAEA’s licence condition compliance arrangements, it is not an ideal position for the longer term. However, it meets the needs of using the flask for the short term until it is withdrawn from service, which is due to occur in March 2007, when it will be replaced by new ones that have been designed to modern standards. UKAEA has been requested to clarify the provenance of one particular operating limit for the flask, which was not immediately apparent, but otherwise the documentation sampled was found to be in order.
NII and the Environment Agency continued to meet with UKAEA on a monthly basis by videoconference. The meetings help maintain close contact with the site whilst reducing travel time and costs. They are not seen as a substitute for site inspection visits but they allow routine regulatory business to proceed while the Site Inspector is away from the site.
A mid year review of safety and environmental matters was conducted with UKAEA. The review was undertaken in the company of a Site Regulator from the Environment Agency. A Safety Representative and the site’s own UKAEA Internal Regulation Department inspector also participated. The review covered relevant health, safety and environment matters associated with the progress and activities on the site that had occurred since the March Annual Review of Safety (NII’s Q1 report refers). No new issues were identified during the review. NII will continue to take a keen interest in all UKAEA’s safety-related activities, including the proposed restructuring of the company and its progress at Harwell with delivering on time revised modern standard safety cases.
The Site Inspector and a Fire Surveyor from HSE’s Hazardous Installations Directorate witnessed an unannounced fire drill in the building, which demonstrated the adequacy of the new building fire evacuation arrangements. The successful test brings to a close HSE’s heightened regulatory interest in the overall subject of fire safety within the building. For the future, current occupancy patterns within the building will change as UKAEA goes about the task of decommissioning the various parts of the building. UKAEA is aware of the need to consider how this may affect both current fire precautions and evacuation arrangements in its decommissioning safety case and associated modifications. NII will continue to take an interest in this work as part of its normal regulatory business across the site.
In previous NII reports to the Local Stakeholder Group, the subject of delicensing has been addressed under the heading of Non-Routine Matters. UKAEA’s withdrawal strategy from the site, as explained in the Harwell Lifetime Plan, will inevitably bring with it more work to delicense areas of the site as these become demonstrably free from the danger of ionising radiations following the completion by the company of decommissioning and ground remediation work. Consequently it seems appropriate now to deal with the subject of delicensing as a routine matter for the site.
The Pilot Area delicensing case has been assessed as demonstrating that the proposed area is free from danger from ionising radiations. Final work was undertaken in September to complete NII’s assessment of the case and to issue the necessary variation to the site licence. The work brought to light the need for UKAEA, in its management of radioactive material movements across the site, to make a distinction in its procedures between areas of the site which continue to be part of the licensed site, and the Pilot Area, which is no longer part of the licensed site even though it remains inside the site security fence. Such a distinction is necessary in order to ensure on-site radioactive material movements continue to be covered by an appropriate safety case. In the case of the Pilot Area, which is now located off the licensed site, the case must comply with Department For Transport approval requirements for flask movements taking place in the public domain.
As well as granting the licence variation, HSE has also issued a notice to UKAEA stating that it is of the opinion that the Pilot Area is free from danger from ionising radiations. This notice ends UKAEA’s period of responsibility for third party damage liability for the Pilot Area but because the company was the licensee at the time when the site was delicensed, it remains liable for the next thirty years for any third party liabilities that subsequently may come to light and which arose during its period as the licensee.
The case for delicensing a second parcel of land known as the North Gate Area has already been submitted to NII by UKAEA following extensive survey work undertaken by the company. NII is now assessing the adequacy of the case and as part of this work it will be carrying out its own independent sampling of the area to assist its judgment of the UKAEA case. As was the case for the Pilot Area, when NII is satisfied with the delicensing case, the North Gate Area will be inspected to identify the location for the necessary site licence boundary signs before the area is delicensed.
The Site Inspector accompanied a specialist inspector from HSE’s Field Operations Directorate in an inspection of conventional safety performance within UKAEA. The inspection was undertaken within the context of HSE’s Revitalising Health and Safety drive. The drive is about injecting new impetus into better health and safety in all workplaces through:
Details of HSE’s Revitalising Health and Safety campaign may be found at www.hse.gov.uk/revitalising/index.htm.
The inspection explored and tested the links from UKAEA’s health and safety policy and procedures through to their implementation in the workplace for the various areas of interest, which included working at height, manual handling, noise, and roads and traffic management. The inspection confirmed a good standard of compliance with the legislation.
NII has powers under Nuclear Site Licence Number 47 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. No licence instruments were issued during quarter three.