Office for Nuclear Regulation

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Dounreay planned compliance inspection

Executive summary

Purpose of Intervention

The purpose of this inspection 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.

Interventions Carried Out by ONR

This intervention included an inspection of the licensee's arrangements for compliance with the following LCs:

The inspections were undertaken by the site inspector and were based on examining a sample of the licensee's arrangements and their implementation on site as follows:

The site inspector also carried out an inspection of the inactive commissioning process for the Prototype Fast Reactor (PFR) raffinate immobilisation project in the Dounreay Cementation Plant (DCP).

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A

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

Overall the site inspector considered that the invitation to tender provides the basis for the development of arrangements that will ensure that DSRL retains overall responsibility for (and control and oversight of) the nuclear and radiological safety and security of work; contractor staff are familiar with the nuclear safety implications of their work and interact in a coordinated manner with DSRL staff; and the work is carried out to the required level of safety and quality.

The site inspector judged that DSRL has a systematic process for managing the effects of the severance programme, with a safety and environment overview report providing an analysis of the cumulative impact of the organisational changes and a Transition Team being set up to provide oversight. However, in this instance the process was not initiated early enough to inform the programme of changes and is instead being used to manage its consequences. ONR therefore requires the licensee to develop a contingency plan to mitigate any adverse effects that may be identified.

The site inspector considered that inactive commissioning of the PFR raffinate modifications has been completed in accordance with the licensee's due process, and that those reservations that were identified were of minor safety significance and have been handled appropriately.

Conclusion of Intervention

Overall, the site inspector considered that the arrangements for compliance with LC17 met with the required standards. He considered that, while there are arrangements for compliance with LC36, they were not initiated early enough to inform the voluntary severance programme and instead are being used to mitigate its effects. He therefore placed an action on DSRL to produce a contingency plan.