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 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 UKAEA Harwell licensed site. 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 normally attend LSG meetings and will be happy to respond to questions raised there by members of the LSG. Any other person wishing to inquire about matters covered by this report should contact the HSE’s Nuclear Directorate on 0151-951-4103.
The Site Inspector made two planned visits to Harwell during the quarter. His inspections and discussions focused on the two topics of the forthcoming UKAEA reorganisation and the Life Time Plan for the site. He also met with the Safety Representatives.
The Site Inspector also met with UKAEA staff representing both Winfrith and Harwell at their Warrington office for discussions on the way forward for the safety submission for their clustered future as Research Sites Restoration Ltd. Further information on matters of interest is provided in the following sections of this report.
As indicated in paragraph 1 above, these were very much focused on the two main areas of NII concern on the site at the moment, which are the UKAEA reorganisation and UKAEA’s continued ability to demonstrate that it is doing all that is reasonably practicable (ALARP) to reduce the hazards across the site in the light of the funding cuts that it has already experienced and those which it is facing for the future. Each topic is dealt with separately below.
NII and the Environment Agency continued to meet with UKAEA on a routine basis by videoconference. The meetings help maintain close contact with the site whilst reducing travel time and costs. They are not seen as a substitute for site inspection visits but they allow routine regulatory business to proceed while the Site Inspector is away from the site.
The Site Inspector has attended two meetings which were held jointly with UKAEA, NDA and the Environment Agency (EA), at which UKAEA has explained the impact of the NDA funding cuts on its Life Time Plan (LTP) for both Harwell and Winfrith. The impact of the cuts is significant and has required UKAEA to change aspects of the decommissioning strategy as well as the scope of associated work packages. Significant elements of the originally proposed decommissioning work will now be delayed for a number of years. Overall, UKAEA is still proposing to complete the decommissioning and remediation of the sites albeit now to much longer timescales. The work in question is a significant component of all of the work which was included in LTP 06/07.
At the time of LTP 06/07, the plan was seen by NII as being a demonstration by UKAEA that the company was doing all that was reasonably practicable to reduce hazards across the site. This, in connection with both Government policy and Nuclear Site Licence Condition LC35, Decommissioning. Together, these require UKAEA to undertake decommissioning as soon as reasonably practicable taking account of all relevant factors, with the objective of progressively and systematically reducing the hazards across the sites, achieving the passive safety of radioactive wastes and completing the restoration of both sites. Because of the clear demonstration of these objectives in the plan, it was accepted by NII at the time (with one or two minor reservations) and it has since been published, but UKAEA is now reporting that it cannot keep to the plan or many of its declared timescales. Indeed, in the case of Winfrith, it may well prove to be the case that UKAEA will propose to place the site in long term care and maintenance, thereby “mothballing” the site and bringing a long term halt to the successful programme of decommissioning and land restoration work that is being undertaken there.
Under the circumstances, and given the overriding duty under health and safety legislation of UKAEA to do all that is reasonably practicable reduce hazards across the site, the company has been requested to provide details of all the work that will not now be undertaken or that will still be undertaken but now to longer timescales. This will allow NII to clearly identify the gap that exists between the LTP 06/07 plan and the current UKAEA proposals. NII will then be able to assess whether UKAEA has moved from a position of compliance with LC35 requirements, which was the case for LTP 06/07, to one of non compliance now, in which case NII will take appropriate action in accordance with HSE’s Enforcement Management Model (EMM).
The reorganisation has continued to be the subject of a number of meetings between UKAEA and NII at both site and corporate level. NII has continued to press the case of the need for the Site Licence Company to be sustainable in its own right and into the future in terms of both resources and expertise, and agreement in principle has now been reached concerning the main issues, subject to the adequacy of their supporting justifications and substantiations. UKAEA is rewriting much of the baseline resource structure and competence substantiations in the light of NII’s views on its first submissions and also now in the light of the funding cuts which are being imposed by the Nuclear Decommissioning Authority (NDA). Rewriting the submission represents a substantial piece of work for UKAEA but the company is aiming to complete its resubmission to NII by the end of July.
NII has powers under Nuclear Site Licence Number 47 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 UKAEA for complying with those conditions.
A new numbering system was introduced on 1 October 2004 for site licence actions, and all such actions are now called Licence Instruments. No licence instruments were issued during quarter two.
Nuclear Safety Directorate
Health and Safety Executive
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