Office for Nuclear Regulation

This website uses non-intrusive cookies to improve your user experience. You can visit our cookie privacy page for more information.

Inspection of the DSRL corporate arrangements for LC23, LC24 and LC26

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 2018/19 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 site’s arrangements made under the following LCs:

I undertook the inspection supported by the ONR Dounreay nominated site inspector.  It was based on examining a sample of the licensee’s arrangements and their implementation on site. The inspections covered the implementation of those LC23, LC24 and LC26 arrangements in support of the following projects:

The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.

This intervention provided the opportunity to conduct a plant visit to PFR against the requirements of LC26 [Control and supervision of operations].  It also provided the opportunity to discuss the licensee’s progress on the Shaft & Silo Project and the Water Vapour Nitrogen (WVN) Project.

Additionally, this intervention provided the opportunity to have a meeting with DSRL’s Senior Manager (Resilience) regarding the upcoming Level 1 Demonstration Exercise (DELTA 54) scheduled for September 2018.

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A

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

There were no significant findings identified during my inspection of the licensee’s implementation of arrangements for LC 23 within the DCP and D1204.  I did note that the Operating Rules were clearly stated and justified within the safety documentation.  Nevertheless I identified a shortfall in the identification of operating procedures implementing an Operating Rule and requested the licensee to review their documentation appropriately.  This will be placed on the Agreed Regulatory Action register.

For these reasons, and on balance, I consider an inspection rating of Green (no formal action) is merited against LC 23 as a result of this inspection.

There were no significant findings identified during my inspection of the licensee’s implementation of arrangements for LC 24 within the DCP and D1204.  I noted that the licensee had employed good practice within the operating procedures to explain why Operating Rules had been adopted informing the operator of the potential hazard of non-compliance.  Nevertheless I determined that within the sampled operating procedures it was not clear that the Operating Rules were being observed by the operator as required by the safety case.  This will be placed on the Agreed Regulatory Action register.

For these reasons, and on balance, I consider an inspection rating of Green (no formal action) is merited against LC 24 as a result of this inspection.

There were no significant findings identified during my inspection of the licensee’s implementation of arrangements for LC 26 within the DCP and D1204.  I determined that the control and supervision of the tasks by the duty supervisor was adequate based on sampling a number of check sheets and response to my questions.

For these reasons, and on balance, I consider an inspection rating of Green (no formal action) is merited against LC 26 as a result of this inspection.

This inspection provided an opportunity to conduct a plant visit within PFR. There was clear evidence of work progressing to clear the areas around and adjacent to the reactor top to support the forthcoming WVN operations and a marked improvement in housekeeping in general throughout the reactor hall.  During this visit I also considered there to be a clear demonstration of supervisor competency and control in support of Irradiated Fuel Cave operations.

This inspection also provided the opportunity to discuss the forthcoming Level 1 Demonstration Exercise. I am satisfied that the objectives set by DSRL and considerations regarding the development of the scenario for this exercise reflect the level of challenge expected by ONR for a demonstration of their emergency arrangements. 

Conclusion of Intervention

My findings were shared with and accepted by the licensee as part of normal inspection feedback.  Overall, I consider that the arrangements and their associated implementation for LC23, LC24 and LC26 for the areas inspected met with the required standards.

However I have raised an Agreed Regulatory Action due to a shortfall in the identification of operating procedures implementing an Operating Rule.  I have raised a further Agreed Regulatory Action to review how the licensee demonstrates compliance with the Operating Rules within the operating procedures.