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 Integrated Intervention Strategy (IIS) for Dounreay to confirm that the licensee is controlling its hazards and complying with its statutory obligations.
This intervention 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 on site as follows:
This intervention also provided the opportunity to conduct a plant visit to PFR against the requirements of LC26 [Control and supervision of operations].
The inspection against LC21 focussed on the implementation of the corporate arrangements for commissioning in support of the PFR raffinate project. We considered that the licensee has robust arrangements for commissioning the plant, processes and people affected by the PFR raffinate modifications.
The inspection against LC22 focussed on the corporate arrangements for the categorisation of modifications and experiments on existing plant and the implementation of those arrangements in support of projects within the fuels directorate. The licensee was able to demonstrate that it had a process in place to ensure that modifications were categorised appropriately, by suitably qualified persons. For all the modifications sampled, the licensee was able to provide an extensive support file to underpin the categorisation and subsequent safety assessment.
The inspection against LC25 focussed on the implementation of the corporate arrangements for operational records in support of site wide maintenance activities. Representatives from the senior maintenance management team demonstrated a good understanding of the licence condition requirement and provided evidence of the training provided to their new staff and contractors on those requirements. DSRL have also appointed a Maintenance Authority (MA) responsible for undertaking independent reviews against planned and corrective maintenance. A sample of the maintenance records examined did not meet the standards considered to reflect relevant good practice and a regulatory issue has been raised to monitor DSRL's resolution of this matter.
This inspection provided an opportunity to conduct a plant visit within PFR, during which we considered there to be a clear demonstration of adequate control and supervision of the operations observed ongoing within the facility.
This inspection also provided an opportunity to conduct an initial review of DSRL's arrangements for the care and maintenance of its infrastructure with a specific focus on ageing buildings. A more detailed examination of the arrangements will now be scheduled during 2018.
During this intervention, the inspectors took the opportunity to meet with the site safety representatives and to attend the scheduled quarterly business meeting of the Dounreay Site Stakeholders' Group.
Overall, we consider that the arrangements and their associated implementation for LC21 and LC22 for the areas inspected met with the required standards. We consider that the implementation of the arrangements for LC25 in support of site wide maintenance activities did not meet the specific legal requirements for LC25(1) but without prejudice to overall nuclear safety or security objectives. We did not identify any matter impacting on nuclear safety that required immediate regulatory action.