Research Sites Restoration Limited (RSRL) Harwell site report - Q3 2009

Harwell Chilton campus local stakeholder group quarterly report for 1 July to 30 September 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 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 RSRL Harwell nuclear licensed site. These reports are distributed quarterly. The Site Inspectors of HM Nuclear Installations Inspectorate (NII) normally attend LSG meetings and will be happy to respond to questions raised there by members of the LSG.

Inspections

The NII Site Inspector visited the Harwell site on the following dates for this reporting period:

14th - 17th July 2009

Further interactions with the Licensee were progressed by videoconference.

Routine matters

The NII Site Inspector has regulated nuclear safety on the site in support of ND's mission to protect people and society from the hazards of the nuclear industry through a programme of planned compliance inspections against Licence Conditions (LCs) attached to the Nuclear Site Licence and targeted interventions supporting regulatory oversight.

Events on the site LC 7

No significant events concerning nuclear safety have occurred over this reporting period. The Inspector noted that a further cable strike occurred on the site. Although minor in nature it highlights that learning from the previous events on RSRL sites has not been adequate to prevent this further event. RSRL have again undertaken an investigation and have strengthened their arrangements.

Inspection of Liquid Effluent Treatment Plant

An inspection of the Liquid Effluent Treatment Plant (LETP) was carried out as part of the programme of compliance inspections and targeted interventions. The Inspector noted progress being made on the emptying of low level radioactive liquid effluent from storage tanks within the LETP. The Inspector highlighted the need for RSRL to ensure external storage tanks containing small amounts of low level radioactive residues were protected from environmental degradation leading to potential leakage. RSRL gave reassurance that the situation was being monitored with work being undertaken to progress the decommissioning of these items. The Inspector carried out a compliance inspection of Operating Instructions LC24 used in the waste encapsulation plant in the LETP. The instructions were found to be adequate.

RSRL Life Time Plan

The Inspector held discussions with RSRL over its Life Time Plan for its Harwell and Winfrith sites. He restated ND's requirement for an adequate safety case at all times, including during decommissioning, which identifies hazards and the control measures needed to reduce risks to as low as reasonably practicable. . The Inspector highlighted the possible need for capital expenditure in maintaining key facilities to prevent significant degradation during extended decommissioning periods and the need for adequate monitoring of these facilities.

Nuclear Baseline

The Inspector held discussions with RSRL on staffing levels within their operational facilities. The Nuclear Baseline providing the means by which the licensee demonstrates that its organisational structure, staffing and competencies are, and remain, suitable and sufficient to manage nuclear safety throughout the full range of the licensee's business. RSRL were able to show how they complied with their Nuclear Baseline requirements. These did not appear to be fully consistent over all their operational facilities on the Harwell site. The Inspector highlighted the need to maintain an adequate Nuclear Baseline and ensure identified staff are suitably experienced and knowledgeable about their role and responsibilities.

RSRL reported that they had followed their LC 36 Control of Organisational Change arrangements and that their Assurance Manager would increase monitoring of the safety performance in facilities where operational management changes had occurred. The Nuclear Baseline is very important in maintaining the high degree of nuclear safety required of RSRL and an effective health and safety policy. The Inspector is conscious of organisational change as a result of RSRL's decommissioning programme and will maintain vigilance over this area.

Meetings with Safety Representatives

The Inspector, as part of his regular business when visiting site, held a meeting with the senior RSRL Harwell Safety representative. No issues were raised at this meeting that required the Inspector to contact the RSRL Safety and Environment Director.

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Non-routine matters

No Non-routine matters occurred over this reporting period.

Proposed changes to the status of HSE's Nuclear Directorate

Government has decided to restructure HSE's Nuclear Directorate (ND) to improve further its organisational framework for the sustained delivery of robust, effective and efficient nuclear regulation in the UK. This will place the ND in a better position to meet the anticipated future challenges.

Several factors have come together to make now the right time to restructure ND and create a new independent Nuclear Statutory Corporation (NSC) under the auspices of HSE. These include changing requirements of ageing nuclear power reactors; on-going decommissioning and active management of legacy nuclear plants; assessment of potential new nuclear power stations; growing competitiveness in the global nuclear skills market and the need for improved regulation driven by increased expectation from society for better accountability, transparency and efficiency from public sector bodies.

In addition to this was the government-initiated exercise conducted by Dr Tim Stone which examined the UK's nuclear safety regulatory regime and identified a number of recommendations for improvement, including the need for structural changes to ND. The Summary Recommendations and the Government's response were published at the end of January 2009 (available on HSE's website).

HSE is working on the legislative measure that needs to be in place to create the NSC. These changes will be made through a Legislative Reform Order (LRO) under the Legislative and Regulatory Reform Act 2006.

Informing this, a joint consultation exercise was carried out by Department of Energy and Climate Change (DECC) and Department for Work and Pensions (DWP) that sought views on the proposed changes. The 12-week consultation period ended on 22 September 2009 and submissions are currently being assessed.

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.

These reforms are designed to lead to improvements in the transparency, accountability and consistency of regulatory activities, thereby seeking to enhance the confidence of all stakeholders, both duty holders and those with wider interests. The reforms would be expected to offer clear and direct benefits to industry and workers as well as society as a whole, which would benefit from efficient and continued robust and effective regulation of nuclear hazards.

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 when permitted by Parliamentary approval as a statutory corporation from spring 2010. This programme has identified key areas of action and deliverables, which will sit alongside the current business improvement programme and will ensure that operational business improvements are delivered alongside the set up of the new corporation.

It is important to recognise that this programme does not in anyway compromise the current business activity that is delivered through ND and strives to improve operational effectiveness and stakeholder engagement.

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Regulatory activity

NII has powers under Nuclear Site Licence Number 84 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 RSRL for complying with those conditions. These are known as Licence Instruments. Licence Instrument

No. 505 was issued on 23 September 2009 giving consent to the licensee's proposal to grant a licence to Computer Sciences Corporation to occupy part of a building.