AWE Aldermaston and Burghfield - Q2 2009 report

Quarterly Report for 1 April to 30 June 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:

April: 1, 20 - 24
May: 11 - 14, 16,17
June: 2, 3, 11, 12, 15 - 19, 30

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.

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
Duly Authorised and other Suitably Qualified and Experienced People
Operating Rules
Operating Instructions
Operational Records
Control and Supervision of Operations
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.

Burghfield

In line with the permissioning strategy adopted at Burghfield, NII issued Licence Instrument No. 518 to allow AWE to undertake live operations in Burghfield. This followed the demonstration of satisfactory progress being made against a schedule of agreed deliverables.

Since the issue of this Licence Instrument, and in recognition of the improvements made over the last couple of years, AWE has been informed that NII has now lifted 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.

NII also issued Licence Instrument No. 519 to release the Hold Point to allow full operation of the Loading Bay.

Separately, significant progress has been made under the enabling works project to prepare the site for construction of the new assembly building.

Aldermaston Demonstration Emergency Exercise (SITEX 2009)

A team of NII inspectors observed SITEX 2009 on 3 June 2009. The purpose of the exercise was to demonstrate the adequacy of AWE plc's emergency arrangements, as required by nuclear site licence condition 11, to deal with any accident or emergency arising on the site.

NII considered the exercise to be an adequate demonstration of AWE's emergency arrangements in response to the postulated event at the Aldermaston site.

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.

Non-routine matters

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.

NII attended a planning meeting with Basingstoke and Deane Borough Council (BDBC) 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. However, BDBC Development Control Committee resolved to grant permission at its meeting on 1 July 2009. This decision was contrary to the Council's Planning Officer recommendation of refusal; which was based partly on NII's stated position.

Event in facility undergoing decommissioning

AWE notified NII of an event involving the spread of a small amount of contamination in a facility undergoing decommissioning.

NII carried out a preliminary investigation into this event and we were satisfied that AWE's response to the event was appropriate.

AWE is undertaking its own investigations into the event to establish if any lessons can be learnt. NII will expect to be appraised of the outcome of this investigation.

Proposed changes to the status of HSE's Nuclear Directorate

The Government has put forward proposals to change the status of HSE's Nuclear Directorate (ND) to that of a Statutory Corporation under the auspices of the HSE. This is intended to enable ND, as the independent nuclear regulator of safety and security, to better meet the challenges of a changing nuclear industry over the coming years. The changes are to provide the nuclear regulator with greater flexibility and increase the accountability, transparency and openness of nuclear regulation. The Government are proposing that the statutory changes needed to bring this about will be made by a Legislative Reform Order (LRO).

This builds on the outcome of the Government initiated review of the UK's nuclear regulatory regime, led by Dr Tim Stone. The Summary Recommendations and the Government's response were published at the end of January 2009.

A public consultation, run by DWP and DECC, on the LRO was launched on June 30th for a 12 week period, which gives the opportunity for stakeholders to comment on the proposals.

These new arrangements 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.

Subject to the outcome of the consultation and Parliamentary approval, and if the Parliamentary timetable permits, the aim is to bring the new body into being during 2010.

An internal change programme is currently operating within ND to ensure that the ND is ready to operate as a statutory corporation from spring 2010.

This programme does not in anyway compromise the current regulatory activities of ND.

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: