AWE Aldermaston and Burghfield - Q1 2009 report

Quarterly Report for 1 January to 31 March 2009

Inspections
Routine matters
Non routine matters
Regulatory activity

Foreword

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.

Inspections

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.
HSE/NII inspections were carried out on the following dates:

January: 19 - 22

February: 16 - 19, 23, 24

March: 12, 16 - 20, 31

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.

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Routine matters

Inspections are undertaken for the purpose of monitoring compliance with

the conditions attached by HSE/NII to the nuclear site licences,
other relevant provisions of the Health and Safety at Work etc Act 1974, and
regulations made under the HSWA, for example, the Ionising Radiations Regulations 1999 and the Management of Health and Safety at Work Regulations 1999.

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:

Reporting of incidents on the site
Training
Duly Authorised and Suitable Qualified and Experienced Persons
Operating Rules
Operating Instructions
Control and Supervision
Safety Mechanisms Devices and Circuits
Examination, Inspection, Maintenance and Testing
Control of Organisational Change

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.

Changes to an Operating Rule

AWE submitted safety documentation to NII, in accordance with its nuclear site licence arrangements, requesting our formal agreement to a change of an Operating Rule. This was required to achieve consistency with the proposed new Operational Safety Case for the existing facility. NII issued Licence Instrument No. 518 agreeing to this change.

Burghfield

In line with our current permissioning strategy, NII issued two Licence Instruments (Nos. 516 and 517) to allow AWE to undertake live operations in certain identified buildings at Burghfield following demonstration of satisfactory progress against a schedule of agreed deliverables.

NII has been encouraged that sufficient progress has been made by AWE in addressing the shortfalls against modern standards identified by AWE for the existing facilities at Burghfield as a result of the Periodic Review of Safety; although the ALARP solution is the construction of modern facilities.

In recognition of the improvements made, AWE has been informed that NII is minded to lift the permissioning regime for live working at Burghfield. This will allow AWE to undertake routine operations without the need to seek formal agreement from NII.

Decommissioning arrangements

NII has developed the strategy it adopts in the regulation of AWE's decommissioning activities on the AWE nuclear licensed sites of Aldermaston and Burghfield. The previous strategy required AWE to produce plans for decommissioning activities on their sites, which were then formally Approved by NII. However, this approach was judged by NII to be overly restrictive as it is recognised that to secure high standards of nuclear safety during decommissioning and react to unforeseen circumstances changes to programmes may be necessary.

NII's revised strategy, which brings AWE into line with the regulatory approach adopted at some other nuclear licensed sites, involves the formal Approval of AWE's arrangements for the production, review and implementation of the decommissioning plans. This approach will enable AWE to manage its decommissioning activities whilst maintaining a strong regulatory oversight ensuring that changes to decommissioning key event timescales are agreed with NII.

To move over to the new regulatory regime NII issued a licence instrument withdrawing its Approval of the existing decommissioning programmes at the Aldermaston site. NII also issued licence instruments to Aldermaston and Burghfield approving the appropriate section of the licensee's decommissioning arrangements.

Land-use planning and nuclear safeguarding zones

As a non-statutory consultee, HSE/NII provides advice to Local Authorities with regard to planning applications in the vicinity of the Aldermaston and Burghfield sites.

In March 2009 HSE/NII met with Basingstoke and Deane Borough Council and a property developer to discuss a proposal for the development of the Boundary Hall site. NII reaffirmed its position to advise against this proposal in recognition of the size of the proposed residential development and its close proximity to the AWE site boundary.

This position is consistent with advice provided previously for the Boundary Hall Site and is based on HSE/NII's current understanding and assessment of the off-site risks presented within AWE's safety analysis.

AWE is currently reviewing its safety analysis presented in compliance with the Radiation Emergency Preparedness and Public Information Regulations (REPPIR). AWE's revised REPPIR assessment may inform NII's consideration of future proposed developments within the Safeguarding and Detailed Emergency Planning Zones.

Non-routine matters

Changes to HSE's Nuclear Directorate

In early 2008 the Government initiated a review into the UK's nuclear safety regulatory regime, led by Dr Tim Stone. The recommendations and the UK's Government response were published at the end of January 2009. One of the major recommendations is the decision by Government to establish the Health and Safety Executive's (HSE) Nuclear Directorate (ND) as a Statutory Corporation under the auspices of the HSE.

The creation of this new, autonomous body, (which will continue to incorporate the Office for Civil Nuclear Security and the UK Safeguards Office) will facilitate a more sustainable approach to regulating nuclear safety and security within a rapidly changing global nuclear environment and recruitment of high calibre of staff within a hardening market place for highly specialised skills.

The restructuring will not change the substance or standards of regulation or compromise the independence of the nuclear regulatory body, and will not affect the decisions it takes or the international obligations the Government requires it to meet.

Enabling work continues for the initial scoping and planning of the work-streams and programmes necessary for the Statutory Corporation to come into being from April 2010. This project has required the temporary enhancement of ND's senior management capability in order to deliver existing regulatory work and to create the Statutory Corporation.

Re-licensing of the Burghfield site

The Atomic Weapons Establishment (AWE) Burghfield Site has been licensed since 1997.

AWE applied for an extension to its nuclear licence at the Burghfield site to accommodate the development of a new assembly/disassembly facility, which is reflected in the agreed long-term strategy for the site. The planned new facility is intended to replace the existing facilities which are approximately 40 years old.

On the 2nd March 2009, Dr Mike Weightman, HM Chief Inspector of Nuclear Installations, signed a new Nuclear Site Licence for the Atomic Weapons Establishment, Burghfield.

Regulatory activity

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:

Aldermaston

Licence Instrument Number 515 was issued in January to Approve AWE's decommissioning compliance arrangements

Licence Instrument Number 517 was issued in January withdrawing a number of previous Approvals of decommissioning programmes previously issued under licence conditions 35(3) and 35(4).

Licence Instrument Number 518 was issued to Aldermaston in February 2009, under licence condition 22, agreeing to the change of an operating rule to ensure consistency with the new Operational Safety Case for a facility.

Burghfield

Licence Instrument No. 515 was issued in January to Approve AWE's decommissioning compliance arrangements.

Licence Instruments Nos. 516 and 517 were issued in February and March respectively to allow AWE to undertake live operations within a facility at Burghfield.

No enforcement notices were issued during the reporting period.