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. 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 person wishing to inquire about matters covered by this report should contact the HSE, Nuclear Directorate on 0151-951-3484/3290.
This report will be put on to the HSE web site at http://www.hse.gov.uk/nuclear/llc/index.htm
Nuclear Directorate
Health and Safety Executive
Redgrave Court
Merton Road
Bootle
Merseyside
L20 7HS
1. The Site Inspector made three planned visits to Harwell during the quarter. His inspections and discussions covered both emergency arrangements and safety cases in B220, but were otherwise focused on the forthcoming UKAEA reorganisation.
2. The Site Inspector was joined by the Site Inspectors for Windscale and for GE Healthcare for the purposes of witnessing the annual NII Level 1 Demonstration Exercise.
3. Further information on matters of interest is provided in the following sections of this report
Planned Inspections and Discussions
4. These were dominated by meetings to discuss the findings from NII’s assessment of UKAEA’s proposals for reorganisation, which is considered below. Otherwise, no planned inspections were undertaken apart from witnessing UKAEA’s Level 1 Exercise Zena. The exercise encountered a number of problems which were explained by UKAEA as being more to do with the planning and running of the exercise than with its ability to respond to an emergency. The company has undertaken to review the issues and to make improvements where necessary, which the Site Inspector will witness during a subsequent site exercise. NII has informed UKAEA that while no additional exercising of emergency arrangements would be necessary on this occasion, nevertheless the expectation remains high that the company is able to successfully stage a Level 1 demonstration exercise for NII which enables a judgment of the adequacy of the arrangements unhindered by problems with staging the exercise.
Remote Contact Meetings
5. Because of the continuing high workload associated with the two matters of LC 35 compliance and UKAEA reorganisation (both separately considered below), NII was unable to join the Environment Agency for routine video conferences with UKAEA. Under the circumstances and if necessary, UKAEA would keep NII informed of significant events through the arrangements it has made under LC 7 for the notification, recording, investigating and reporting of incidents on the site. Other informal communications continue normally..
Licence Condition 35, Decommissioning
6. As was reported for quarters two and three, NII continues to follow up UKAEA’s proposals to significantly cut back on its decommissioning programmes which it declared in LTP 06/07. NII is doing so with a view to determining whether the company has remained compliant with the requirements of LC 35, Decommissioning and, if not, then what enforcement action, if any, would be appropriate under the circumstances and in accordance with HSE’s Enforcement Management Model.
UKAEA Reorganisation
7. Having completed its assessment of UKAEA’s proposals for reorganising Harwell and Winfrith into a stand-alone Site Licensee Company (Research Sites Restoration Ltd, (RSRL)), NII has embarked on a series of meetings with the company in order both to clarify many points of detail within the documentation and to raise a number of safety-related issues across a broad spectrum with which NII is currently dissatisfied. The assessment of the proposals has been hindered by the continuing presence of very many errors and inconsistencies throughout the documentation. While this may be attributable in part to the short timescales which UKAEA is having to work to, it also indicates a pressing need for the company to improve its peer review and Nuclear Safety Committee processes and expectations. Discussions on the remainder of the submission continue with good progress having been made in the two meetings held so far. Where necessary, UKAEA has been requested to provide further supporting documentation either to clarify its proposals or to satisfactorily address a number of concerns. The position, together with the continuing work on LC 35 compliance matters, means that the follow-up assessment work is expected to continue until at least February 2008.
8. In order to secure a set of reorganisation proposals with which it can broadly agree, NII has been unable to avoid a long and drawn out interaction with UKAEA regarding the company’s proposals. Regrettably, this has led to a significant period of uncertainty for members of UKAEA staff. Under the circumstances, and given the good progress that has been made so far with the resolution of issues, the company has been informed that adequate additional supporting documentation, together with the extant submission, would be an acceptable basis upon which NII could proceed in the short term. The extant submission together with the additional supporting documentation will provide NII with the substantive case necessary for it to agree to the company moving towards the new structure and, eventually, when that structure and its processes are demonstrably in place, to a six month period of shadow working. The latter will provide UKAEA (then reorganised into the proposed RSRL structure) with the opportunity to demonstrate that the new structure can work successfully in practice ahead of the granting of new licences to RSRL for Winfrith and Harwell. Notwithstanding NII’s short term position, the company has been informed that it will need to remedy the poor quality of the submission and put it through due process again, in time for relicensing.
9. NII has powers under Nuclear Site Licence Number 44 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.
10. 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 four.