Office for Nuclear Regulation

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LC 17 and 25 compliance inspection

Executive summary

Purpose of intervention

ONR transport and nuclear safety inspectors carried out planned inspections of compliance with licence condition (LC) 17 (management systems), LC 25 (operational records) and the Carriage of Dangerous Goods (CDG) Regulations in accordance with the 2015/16 integrated inspection strategy (IIS) for Dounreay, to provide confidence that the licensee is controlling its hazards properly and complying with its statutory obligations

Interventions Carried Out by ONR

The nuclear safety inspector inspected the licensee's arrangements for compliance with LC 17, particularly with respect to the integration between arrangements made for compliance with the site licence and arrangements made for compliance with CDG. He also inspected records made in compliance with LC 25 for moves made as part of the Dounreay exotics programme.

The transport inspector inspected the following thematic areas from the compliance map: package manufacture (management of the supply chain for GB2816J); radiation protection programme (transport operations); training and competence; Dangerous Goods Safety Advisor (DGSA) advice; and incidents, events and compliance history. In addition the opportunity was taken to discuss how key safety functions would be achieved for packages currently with ONR for approval.

Explanation of Judgement if Safety System Not Judged to be Adequate


Key Findings, Inspector's Opinions and Reasons for Judgements Made

The ONR inspectors examined a number of the site's processes, looking at whether site licence and transport requirements were well-aligned. It was their judgement that the licensee manages the interface between safety and transport requirements and qualifications well.

They also examined a number of records supporting moves made as part of the Dounreay exotics programme, considering them to provide suitable evidence that process steps have been completed satisfactorily, and have been verified as doing so. Where independent verification is provided, it is clear what has been considered and what conclusions have been derived.

The ONR Transport Inspector noted that a DGSA annual report had not been produced recently - the annual report is a requirement of the transport regulations.

Conclusion of Intervention

The inspectors did not identify any matter impacting on nuclear safety that required immediate regulatory action.