Dounreay Site Restoration Limited

Quarterly report for 1 April to 30 June 2009

Inspections
Routine matters
Non routine matters
Proposed changes to the status of HSE's Nuclear Directorate
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 site available to the public. It is for distribution to members of the Dounreay Site Stakeholder Group (DSSG) and covers activities associated with the regulation of safety at Dounreay. 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 Dounreay SSG meetings and will respond to questions raised there by members of the Dounreay SSG.

Inspections

NII Site Inspectors and Specialist Inspectors visited Dounreay on the following dates:-

1st - 2nd April 2009
27th - 30th April 2009
11th - 15th May 2009
15th - 18th June 2009
23rd - 25th June 2009

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Routine matters

Site inspection activities

Compliance inspections were undertaken against Licence Conditions,

14 Safety Documentation,
22 Modification or Experiment on Existing Plant,
23 Operating Rules,
27 Safety Mechanisms Devices and Circuits,
28 Examination, Inspection, Maintenance and Testing and
36 Control of Organisational Change.

No major issues were identified.

A joint NII-SEPA inspection was carried against Licence Conditions

10 Training,
12 Duly Authorised Persons and Suitably Qualified and Experienced Persons,
26 Control and Supervision of Operations and
28 Examination, Inspection, Maintenance and Testing.

No major issues were identified.

A Human Factors specialist from NII visited Dounreay in June to review progress with the integration of Human Factors considerations into the site safety management processes. Whilst good progress was evident during the inspection, improvements were identified for the management of control room alarms at PFR and for the evacuation routes at DFR.

Emergency Arrangements

The annual demonstration of the site emergency arrangements was witnessed by a team of NII Inspectors. The exercise was centred around a hypothetical event in the Fuel Cycle Area that required the immediate evacuation of the area, retrieval of a simulated casualty and the accounting for all persons on the site. The NII team considered that the exercise was an adequate demonstration of the site emergency arrangements.

NII also witnessed the support provided by Dounreay to Vulcan during the Vulcan emergency exercise. This was also considered to be an adequate demonstration of the Dounreay emergency arrangements.

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Non routine matters

DSRL informed NII of a number of failures to follow administrative procedures associated with Licence Condition requirements on the site. There were three instances where proposals to modify plant or safety documentation was not forwarded to NII as required by the arrangements for Licence Condition 22. In addition one facility on the site was found to be operating outside the scope of the safety documentation.

NII Inspectors conducted a thorough examination of these matters and were satisfied that there was no direct challenge to safety arising from them.

NaK Disposal

We continue to monitor the active commissioning programme for the NaK Disposal Plant. The commissioning programme is progressing well and as a result, NII and SEPA have agreed to undertake a joint inspection at the end of August with a view to ending the commissioning phase and allowing DSRL to move into a routine operating mode.

New Liquid Waste Encapsulation Plant and Store

NII held a meeting with DSRL and it’s contractors to discuss encapsulation chemistry and the justification of the longevity of waste packages which could be held in the store for a period of around 100 years or more. No issues were raised on encapsulation chemistry but both DSRL and NII recognise that there is more work to do on the design and requirements of the store ventilation system to demonstrate, as far as is possible, that environmental conditions in the store are such that packages will not significantly degrade.

Fuel Cycle Area Decommissioning

NII is content with decommissioning progress in the FCA area and with the attention being placed on conventional and nuclear safety. This is a developing area and regulatory control will be focused on relatively high nuclear risk areas.

NII has held discussions with DSRL on the production and review of the Safety Case for the decommissioning of Building 1206 and 1234. Progress is being made and it is hoped that decommissioning of these facilities will commence before the end of 2009.

A compliance inspection of maintenance procedures in support of FCA decommissioning activities was undertaken. The inspection found no significant issues and acknowledged the use of good practice through the application of Reliability Centred Maintenance tools and techniques.

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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 is 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 (available on HSE's website: http://www.hse.gov.uk/nuclear/stonereview.htm).

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. For access to this consultation please see http://decc.gov.uk/en/content/cms/consultations/hse_restruct/hse_restruct.aspx

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.

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Regulatory activity

The Inspectorate has powers under the Licence to issue Consents, Approvals and Directions. In addition, the Inspectorate uses Licence Instruments to issue Specifications, Acknowledgements, and Agreements under either the conditions attached to the Licence, or arrangements made by DSRL for complying with those conditions.

No Licence Instruments were issued during the period of this report.