Office for Nuclear Regulation

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Dounreay - LC35 Compliance Inspection and IIS 100 series inspection activities

Executive summary

Purpose of Intervention

The purpose of this intervention was to undertake a Licence Condition (LC) compliance inspection, a safety case informed (project based) inspection and, to conduct a number of other inspection activities 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

The purpose of this intervention was to conduct an inspection of DSRL’s arrangements against the requirements of LC35 [Decommissioning] and to conduct a safety case informed inspection [project based inspection (PBI)] of the projects ongoing within D2001.  The PBI inspected the suitability of the safety case and its implementation against the requirements of the following suite of licence conditions:

This intervention provided the opportunity to undertake a number of other activities, specifically:

Explanation of Judgement if Safety System Not Judged to be Adequate

We consider that safety systems we examined to support the projects underway currently within D2001 to be adequate against the requirements of those licence conditions covered by the PBI.

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

For LC35 we examined the current state of development of DSRL’s overarching decommissioning programme with a specific focus on the interdependencies between the various individual, facility decommissioning programmes and the site’s infrastructure and capabilities.  Although it is clear that the programme is at a relatively mature state of development, DSRL is in the process of conducting a series of verification activities to ensure that these interdependencies have been identified and captured on the programme.  Progress on these activities will be examined during a future planned inspection against LC35.

With regards the PBI conducted within D2001, we examined the staff’s understanding of the key outcomes from the safety assessment of the inspection and storage of irradiated fuel. We then examined how the limits and conditions identified within the safety assessment had been captured and reflected in the associated operating instructions and the maintenance of safety related plant and equipment.  This inspection included a plant visit to D2001 where we took the opportunity to assess the understanding operators had regarding the hazards and associated limits and conditions associated with the activities being undertaken at that time.  Finally we sampled the training undertaken by the ATO Holder and operations staff and examined how the arrangements sampled addressed the requirements regarding the leakage and escape of radioactive material and radioactive waste.

Overall we were satisfied that the limits and conditions and safety related plant and equipment identified within the safety assessment had been adequately captured within the associated operational and maintenance documentation reviewed; that the training records sampled reflect the level of understanding expected of staff (evident in the depth of understanding of hazards and associated limits and conditions demonstrated by staff we interacted with during this inspection); and that the arrangements examined provide an adequate demonstration against the requirements regarding the control of leakage and escape of radioactive material and radioactive waste.

This inspection also provided the opportunity to receive an update on the detailed planning for the site’s forthcoming level 1 annual demonstration emergency exercise.  

Conclusion of Intervention

Overall, we consider that the arrangements and their associated implementation for LC35 for the areas inspected met with the required standards; we are also satisfied that the site is making adequate progress in addressing maters raised in previous inspections.  We also consider that the safety justification supporting the inspection and storage of irradiated fuel within D2001 to have been implemented adequately against the requirements of those licence conditions covered by the PBI.