Office for Nuclear Regulation

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Dounreay - Planned compliance inspection (LC15, LC23 and LC24)

Executive summary

Purpose of Intervention

The purpose of this intervention was to undertake a Licence Condition (LC) compliance inspection at Dounreay Site Restoration Limited (DSRL) in accordance with the 2017/18 Site Integrated Intervention Strategy (IIS) to confirm that the licensee is controlling its hazards and complying with its statutory obligations.

Interventions Carried Out by ONR

This inspection included an inspection of the Site’s arrangements made under the following LCs:

The inspections were undertaken by the ONR Dounreay site inspectors and were based on examining a sample of the licensee’s arrangements and their implementation within the following areas on site:

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A

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

For LC15 the inspectors focussed their inspection on the management of DSRL’s LC15 review programme within the FCA, waste directorate and reactors directorate.  There was clear evidence of lessons learned being identified and implemented within each area with improved ownership of the key technical aspects of the programme.  ONR will expect this learning to be captured within its corporate arrangements for LC15. Although there was evidence of good programme management practice this was not consistently applied across all areas inspected although ONR remain confident that all areas demonstrated adequate management and control of their LC15 review programme.

In conclusion we considered the implementation of DSRL’s arrangements for the management and delivery of their periodic reviews to be an adequate demonstration of their compliance against the requirements of LC15.

The inspections against LC23 and LC24 were conducted in parallel and involved:

The inspections identified a clear demonstration of the line of sight of the limits and conditions [Key Safety Management Requirements (KSMRs) and Safety Management Requirements (SMRs)] identified within the safety cases through to the operating instructions and check sheets used on plant.  There was also clear evidence of an effective management of change process where all operating instructions impacted by a change in KSMRs/SMRs are identified in the associated Dounreay Modification Request (DMR); those changes are then briefed to operators who sign that they have received and understood the brief.

In conclusion we considered the implementation of DSRL’s arrangements for the identification, implementation and control of their KSMRs/SMRs to be an adequate demonstration of their compliance against the requirements of LC23 and LC24.

Conclusion of Intervention

Overall, we consider that the arrangements and their associated implementation for LC15, LC23 and LC24 for the areas inspected were adequate.  We did not identify any matter impacting on nuclear safety that required immediate regulatory action.