SEPA Management of
1 August 03
The Scottish Environment Protection Agency (SEPA) has
announced a number of changes to its internal procedures for regulating
Dounreay. The action follows the recommendations of an inquiry,
commissioned by SEPA, which highlighted weaknesses in communications and
SEPA’s main board commissioned Sir Laurence Hunter of
Glasgow University to carry out the independent inquiry. Sir Laurence was
asked to consider the integrity of the management and communication
systems used by SEPA in relation to Dounreay. He was given complete access
to SEPA staff and documentation. The inquiry report concludes that:
meetings were irregular and ineffective
procedures were absent or inadequate
managers failed to address serious issues
communication between senior managers and the board were ineffective.
Dr Campbell Gemmell, SEPA’s Chief Executive, said: “I want
to reassure people that there is no evidence that the environment has been
put at risk. However, it is not acceptable for an organisation like ours
to neglect the proper processes. Since I became chief executive I have
devoted considerable time to addressing this issue and I will continue
working to secure the improvements we need. I have prepared an action plan
that will ensure we have robust procedures in place for carrying out our
Dr Gemmell continued: “We are currently going through the
process of meeting the challenges set out in the Scottish Executive’s
review of our performance. Many of the recommendations in that review are
related to the issues identified in this inquiry, particularly those on
communication and delegation. We are already taking positive action to
improve our ways of working.”
Chairman Sir Ken Collins, said: “Whilst I am confident that neither the
public, nor the environment, have been put at risk, we are very aware of
our responsibilities to the Scottish community and the Scottish
environment. The high standards we expect of others must apply equally to
our own procedures and practices. That is why the board arranged for this
investigation, and we will now ensure that the appropriate steps are
Sir Laurence’s report also highlights the
integrity and enthusiasm of staff, and a strong core of cultural values
and behaviour on which to build.
The main recommendations of the report are to
there is effective delegation, and that a programme is put in place to
develop best management practice
the communication culture of SEPA at all levels
essential quality and work procedures.
Gemmell’s Action Plan -
SEPA has made significant changes to the authorisation
covering UKAEA Dounreay’s discharges of gaseous radioactive waste. The
changes mean a cut of 41 per cent in the quantity of tritium that the site
is allowed to release to the environment and came into effect on 18 July
2003. The change also permits the operation of UKAEA’s new facility for
collecting and disposing of liquid waste to sea. This facility, known as
the Low Level Liquid Effluent Treatment Plant, will replace the old sea
discharge tanks that were the subject of a SEPA enforcement notice in
required by SEPA to improve the discharge system for gaseous waste from
the main facilities in the fuel cycle area. It will also have to produce a
strategy that will set out
principles for radioactive waste management
how it will manage gaseous waste discharges, and
how it will
comply with the government’s international environmental commitments.
SEPA is also finalising a similar downward
change in the limits controlling liquid waste from Dounreay, where there
is greater scope for reduction. This has been brought about by UKAEA’s
move away from reprocessing, to a mission of restoring the environment.
These are considered to be interim measures while UKAEA finalises its
application for a new
This application will be supported by UKAEA’s plan for the
environmental restoration of the Dounreay site. SEPA will consult the
public about the application and expects that the new authorisation may be
in place by 2005.
Wildlife enforcement notice
We are satisfied that UKAEA has complied with
the first part of enforcement notice. It has
the affected areas and carried out immediate repairs to
fences. Staff are also carrying out regular
s on the integrity of the fence. After UKAEA reported
these actions to SEPA, two officers carried out an inspection. We will
continue to monitor the situation closely.
SEPA served the enforcement notice on UKAEA
in June, requiring measures to limit and prevent access to the site by
wildlife. The site’s authorisation requires UKAEA to use ‘best practicable
means’ for preventing the movement of any radionuclides contained in the
pits. By failing to secure the pits UKAEA has allowed rabbits access to
radioactive waste. Rabbits have the potential to spread radioactivity and
radioactive waste around the site and beyond.
The enforcement notice requires UKAEA to do
several precautionary actions:
take immediate measures to limit wildlife access to the
take long term measures to prevent wildlife from accessing
to the pits
quantify and repair damage caused by wildlife.
enforcement notice also requires UKAEA to carry out surveillance to
demonstrate that the measures have been effective. SEPA will also require
UKAEA to provide further evidence that it has complied with the notice.
SEPA is making a number of changes to its internal
procedures for regulating Dounreay. The action follows the recommendations
of an inquiry, commissioned by SEPA, which highlighted weaknesses in
communications and management systems. SEPA’s main board commissioned Sir
Laurence Hunter of Glasgow University to carry out the independent
inquiry. Sir Laurence was asked to consider the integrity of the
management and communication systems used by SEPA in relation to Dounreay.
He was given complete access to SEPA staff and documentation.
SEPA has already published the outcomes of two of the
research modules, which form part of the contract with NRPB. These are the
analytical study of particles in a simulated human gut and a review of
monitoring procedures at Sandside. There are several modules and work is
ongoing. It will be at least next autumn before all the modules are
complete. SEPA will publish the results of each module on the website as
they are completed. We will not be able to draw any conclusions from the
research programme until all the modules are completed.
An additional Sandside monitoring activity that SEPA is
planning is the profiling of the beach at Sandside. The profile of the
beach, and the changes in that profile, are relevant to understanding the
pattern of particle discoveries at Sandside. It is important for SEPA to
understand how the beach changes with weather conditions and the tides.
Unfortunately, Sandside Estate has not given unqualified permission for
SEPA to access the beach for profiling.
Researchers working on behalf of SEPA have been carrying
out a ‘habit survey’ in the Dounreay area. Habit surveys are essential
radioactivity in food and the environment (RIFE)s. They are carried out near all major nuclear sites and are
used to identify groups of individuals who are most likely to be at risk
from environmental radioactivity (from man-made sources).
of the research are used to decide which materials to sample for
radioactivity and where to take them from. The analysis and interpretation
eventually appear in the annual RIFE reports, published by SEPA and the
Food Standards Agency.
surveys involve, among other things, identifying
local recreational and commercial activities
the use of food and food stuffs
methods used are interviews (of local people and SEPA staff) and
observation (eg at beaches). Representatives of Sandside Estate took part
in the habit survey. The field work was carried out 11 – 23 July. It was
last carried out in 1999.