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 from the Internet at http://www.hse.gov.uk/nuclear/index.htm. Site Inspectors of HM Nuclear Installations Inspectorate (part of the Health and Safety Executive’s Nuclear Directorate) 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’s, Nuclear Directorate on 0151-951-3484/3290
Nuclear Directorate
Health and Safety Executive
Redgrave Court
Merton Road
Bootle
Merseyside
L20 7HS
The Site Inspector made two planned visits to Harwell during the quarter. His inspections and discussions covered a number of regulatory topics including safety cases, modifications, stored waste retrieval and the Life Time Plan for the site.
In November, the Site Inspector was joined by NII colleagues who assisted in the witnessing of the annual NII Level 1 Demonstration Emergency Exercise. In conjunction with the Environment Agency’s (EA) Site regulator, he also attended an NDA (Nuclear Decommissioning Authority) initial joint review of the Winfrith and Harwell Life Time Plans for 2007/2008, which was also attended by the Environment Agency (EA).
In December, the Site Inspector attended a workshop with NDA, EA and UKAEA to discuss the company’s plans for reorganisation which will cluster Harwell and Winfrith together into a single management structure in order to facilitate NDA’s competition of all UKAEA sites (except Culham) in 2008.
Further information on matters of interest is provided in the following sections of this report.
[back to top]As indicated in paragraph 1 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. The retrieval of a particular type of stored intermediate level waste revealed the historical plant records did not accurately record the manner in which the waste had been consigned to its shielded storage tube. The finding by the plant required additional modification safety documentation to be raised to cover the necessary and additional waste characterisation work. This proved to be successful and the retrieval of the waste continued without the need for any further additional documentation.
NII and the Environment Agency continued to meet with UKAEA on a routine 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.
The Site Inspector was joined by the Site Inspectors for Windscale and GE Healthcare for Exercise “ Yana” which was UKAEA’s annual demonstration to NII of its emergency arrangements. The scenario involved the dropping of a radioactive source package in one of the operating buildings, which subsequently required building evacuation, a declaration of a site emergency and roll call, the recovery of a “casualty” and the controlled re-entry into the building in order to safely deal with the exposed source. In pleasing contrast with the 2005 Level 1 Demonstration Exercise, Exercise “ Yana” proved to be an adequate demonstration of emergency arrangements with some strong individual performances by the participating staff. The scenario proposed by UKAEA was extended so that the early stages of the recovery plan were actually implemented in order to achieve a significant reduction of the radiation field. The extended scenario revealed important lessons for UKAEA in terms of contingency planning for reasonably foreseeable accidents, which did not address the particular scenario of a radioactive source becoming exposed inside a building, for which the company has now been requested to draw up appropriate plans.
Into the future, NII will continue to take an interest in UKAEA’s emergency planning and preparedness and will follow up the improvement action plan which was drawn up following Exercise “ Yana”. UKAEA has recently started a review of its emergency arrangements and NII has asked the company to continue to keep it informed of the emerging findings from its review. NII has always seen the need for adequate emergency preparedness as being a precursor to operations that may affect safety on a nuclear licensed site. This is because the emergency arrangements are seen as the ultimate “safety net” in the event of there being some unforeseen failure in all of the other carefully considered safety provisions made on the site. As UKAEA continues to systematically reduce the radioactive waste hazard on the site and to process its legacy wastes into a suitably immobile and passively safe form, it is both inevitable and not unreasonable that the company will wish to review the continuing need to maintain the current levels of emergency preparedness on the site. It is the case that there are now some very large buildings which once housed and processed significant quantities of radioactive material which are now empty of such material and in some cases the buildings are already demolished. For the future, and before any changes are implemented by UKAEA, NII will need to be satisfied that any proposed reorganisation or reduction of emergency preparedness will continue to meet the needs of the site. Any such changes would be subject to continued regulation by NII under Nuclear Site Licence Conditions 11 (Emergency Arrangements) and 36 (Control of Organisational Change).
NII has continued to engage with NDA, EA and UKAEA in joint discussions regarding UKAEA’s proposals to reorganise itself in order to meet HM Government’s requirements for commercially competing all of the UKAEA sites in 2008. Ongoing discussions continue and UKAEA was informed by NII some time ago that there can be no agreement to the company’s proposals until NII is fully satisfied that the proposals for each of the four UKAEA sites are satisfactory (except Culham, which has not been scheduled for competition). The Site Inspector and the Superintending Inspector leading NII’s ongoing assessment of the proposals attended a workshop at Harwell in December. The workshop was held to discuss issues which impact on the formation of the Harwell/Winfrith cluster and which in some cases also apply to other UKAEA sites. At the end of the workshop, UKAEA took away a number of issues for which it has undertaken to provide additional supporting justifications and substantiations. NII remains concerned about the longer-term ability of the site management to remain fully cognisant of all of the safety-related issues and implications associated with both the ongoing and future undertakings on the sites. These matters are otherwise known as the “intelligent customer” and “controlling mind” attributes which NII expects all licensees to be able to demonstrate at all times (see http://www.hse.gov.uk/nuclear/notesforapplicants.pdf [PDF 188kb] for further information). For the future, NII will continue to work with NDA, EA and UKAEA to secure resolution of the remaining issues.
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 four.