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/llc/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 Information Centre on 0151 951 3484.
Nuclear Directorate
Health and Safety Executive
Redgrave Court
Merton Road
Bootle
Merseyside
L20 7HS
HSE/NII inspectors visited the Aldermaston and Burghfield sites on several occasions during the quarter being reported. There were visits from other HSE inspectors in relation to explosives and conventional safety; and, also the Chief Inspector NII made a routine visit to AWE in November 2008.
HSE/NII inspections were carried out on the following dates:
Some of the inspections were carried out with inspectors from the Ministry of Defence internal regulatory organisation, the Defence Nuclear Safety Regulator (DNSR) and the Environment Agency.
Inspections are undertaken for the purpose of monitoring compliance with
This entails monitoring licensee’s actions on the site in relation to incidents, operations, maintenance, projects, modifications, safety case changes and any other matters which may affect safety. The licensees/operators are required to make and implement adequate arrangements under the conditions attached to the licence in order to ensure legal compliance. Inspections seek to judge both the adequacy of these arrangements and their implementation. In this period routine inspections of AWE Aldermaston and Burghfield included:
In general the arrangements made and implemented by AWE Aldermaston and Burghfield were deemed to be adequate in the areas inspected. However, where improvements were considered necessary, satisfactory commitments to address the issues were made by or are being sought from AWE plc, and the site inspector(s) will monitor progress during future visits. Should we feel that progress is unsatisfactory in addressing any issue; the option to take formal regulatory enforcement action could be considered to ensure that appropriate remedial measures are implemented within reasonably practicable timescales.
The Aldermaston annual demonstration emergency exercise was held on 22 October 2008 (SITEX 2008).
Overall, NII considered SITEX 2008 to be an adequate1 demonstration of AWE’s emergency arrangements in response to the postulated event at the Aldermaston site and a number of areas of good performance were noted. However, in line with a culture of seeking continuous improvement, AWE agreed to review its site mustering arrangements, complete improvements to an emergency reception centre and provide NII with a forward action programme.
NII issued two Specifications (one for each licensed site), under licence condition 35 Decommissioning, requiring AWE to submit to NII for Approval its arrangements to meet this condition. This will remove the requirement for the regulatory Approval of specific decommissioning plans.
This action will ensure a similar regulatory approach adopted with a number of other nuclear licensees; and is intended to provide more flexibility and better targeting of resources in the regulation of decommissioning projects. Additionally, this will bring decommissioning activities into line with the flexible permissioning approach used by NII to regulate the operational nuclear facilities on the AWE sites. The approach retains NII’s regulatory powers to influence decommissioning activities.
AWE submitted an application together with supporting safety documentation for HSE/NII’s agreement to extend the period of active commissioning for a specific process.
HSE/NII concluded that the safety justification was adequate and issued a Licence Instrument agreeing to this extension, but with a clear expectation that the process moves to a routine operation supported by appropriate safety documentation in the next 6 to 12 months.
Dr Weightman, the Chief Inspector of Nuclear Installations, visited the Aldermaston and Burghfield sites on 12 November 2008 to meet with AWE Directors and other key staff, including Safety Representatives.
As part of this visit Dr Weightman was able to observe the significant progress made by AWE in the refurbishment of a number of its major facilities.
1 The conditions attached to the Nuclear Site Licence require the licensee to make and implement “adequate” arrangements. Since this is the word used in the legislation it is therefore the word normally used by HSE/NII inspectors to indicate that the requirements of the law have been met. It should not therefore be construed as meaning a poor or barely acceptable performance has been achieved.
During the reporting period BNFL agreed to the sale of its one third shareholding in AWE Management Limited (AWEML) to the Jacobs Engineering Group. AWEML owns the licensee company AWE plc.
Although MOD owns the Aldermaston and Burghfield sites; AWE plc as the nuclear licensee, operates both sites on its behalf. The previous ownership of AWEML; which was set up in 2000, was equally shared between BNFL, Serco and Lockheed Martin. MOD will retain ultimate control of the company by the provision of one special share held by the Secretary of State for Defence.
As part of its routine site inspection activities at the Aldermaston and Burghfield sites, NII has been kept updated about the transfer of BNFL’s one-third shareholding in AWEML
NII is content that AWE plc has undertaken a proportionate organisational change justification, in accordance with its Licence Condition 36 arrangements, in relation to the expected changes in AWEML.
As a follow up to the change of ownership NII will continue to monitor the performance of AWEML and AWE plc to ensure nuclear site licensing and safety responsibilities continue to be a priority and are discharged in line with regulatory expectations.
In the period being reported on, HSE/NII has received and responded to further FoI requests for information related to regulation of AWE. HSE/NII supports making appropriate information available to the public and other interested parties in relation to operations at the Aldermaston and Burghfield sites.
HSE/NII has provided regular updates to the LLC on the Improvement Notice that had been served on AWE on 3 April 2008, to secure improvements in AWE’s licence condition 23 and 24 arrangements dealing with criticality control arrangements. The notice required improvements to a number of key processes by January 2009.
NII received a letter from AWE on 18 December 2008 stating that it considered that requirements of the Improvement Notice had been met. Based upon a number of specific inspections NII confirmed to AWE that we were satisfied that they had demonstrated adequate compliance with the requirements of the Improvement Notice, which allowed it to be closed. AWE’s arrangements within this area now compare well with NII’s benchmarked guidance.
AWE applied to West Berkshire County Council for planning permission for the construction of a new assembly/disassembly facility (MENSA) at its Burghfield Site. This supports the conclusions made within the Periodic Review of Safety for future operations of this nature.
Separately, AWE applied to NII for an extension to the current nuclear licensed site boundary at Burghfield on 31 October 2008. An application to NII was required since the area proposed for the new facility is located outside the existing nuclear licensed site boundary. We are currently assessing AWE’s justification to extend the nuclear licensed site boundary with a view to relicensing the site early in 2009.
NII gave a general presentation on ‘Regulating the Hazards of the Nuclear Industry’ to members of the Nuclear Awareness Groups and Nuclear Information Service on the evening of 16 December 2008 at Reading Civic Centre.
Under Health and Safety legislation, HSE/NII Site Inspectors and other HSE Inspectors, may issue formal documents to ensure compliance with regulatory requirements.
As part of its regulation under the nuclear site licences NII issues formal regulatory documents called Licence Instruments. These utilise the primary licence condition powers of `Consent', 'Approval', 'Direction', 'Specification', 'Notification' and 'Agreement' as well as those powers derived from the licensee's arrangements.
The following Licence Instruments were issued during the period of this report:
Licence Instrument Number 514 for Aldermaston and Number 514 for Burghfield were issued in October 2008, under licence condition 35, specifying the licensee to submit its compliance decommissioning arrangements to NII for Approval.
Licence Instrument Number 516 was issued to Aldermaston agreeing to an extension of the commissioning period for a specific facility.
No enforcement notices were issued during the reporting period that were not covered in our previous report.