Office for Nuclear Regulation

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Dounreay - Level 1 Demonstration Exercise, IRR17 and LC compliance inspections

Executive summary

This was one of a series of planned inspections of arrangements made under Licence Conditions (LC) by 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 assessment of the Site’s annual demonstration emergency exercise Delta 54 conducted against the requirements of LC11(5) [Emergency arrangements].

This intervention also included an inspection of the site’s arrangements made under Ionising Radiation Regulations 2017 and the following LCs:

The inspections were undertaken based on examining a sample of the licensee’s arrangements and their implementation on site. The IRR17 and licence condition inspections covered the implementation of those arrangements within:

This inspection also provided the opportunity to receive an update on progress against other matters requiring action by the licensee and progress on the contract mobilisation supporting the DFR Residual NaK removal project.

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A

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

The LC7 compliance inspection focused on those areas discussed at the previous inspection carried out in Dec 2017.  There is clear evidence that DSRL has implemented a number of initiatives recently to improve the learning gained from operational experience and these will be assessed during future LC7 inspections. In particular, we acknowledge DSRL’s commitment to ensuring that all personnel on site undergo MINDSAFETY training with a number of site personnel trained as MINDSAFETY coaches.  We also acknowledge DSRL’s on-going review of the courses available within the construction industry (CITB) to improve the training and competency of project supervisors in the area of control and supervision of operations.

The LC8 compliance inspection identified the adequate control of warning signs in high hazard facilities which were reviewed annually as part of their self-assessment report arrangements. Additionally, the general warning notices around the site were considered to be appropriate to the hazard at those locations and were in a suitable condition. The site also makes effective use of digital media to convey important safety information to personnel as they enter site and via their workplace IT systems.

For LC9 we examined the corporate arrangements and their implementation.

Overall we are satisfied that DSRL’s arrangements for LC7, LC8 and LC9 demonstrate compliance against the legal requirements. In addition we also consider that adequate progress is being made in those aspects of the site’s arrangements for LC7 where we have agreed there to be areas for improvement.

The inspection against the IRRs focused on the progress to date in updating arrangements against the requirements of IRR17 and the organisational structure supporting those arrangements.  In each of the areas inspected we identified that a suitable and sufficient level of SQEP resource was available and that training was in date. In addition there was evidence of programmes in place to develop and qualify a number of new health physicists and RPAs.  During our plant visits we examined the local rules and found them all to have been updated to reflect the requirements of IRR17.  We also examined a sample of the contamination monitoring equipment and found it to be fit for purpose and in date for calibration.

Overall, we are satisfied that DSRL has adequate arrangements in place against the requirements of the IRRs and is making adequate progress in updating its documentation to reflect the revised requirements of IRR17.

This intervention provided the opportunity to assess the site’s annual Level 1 demonstration emergency exercise [Delta 54]. Overall we consider that the exercise provided an adequate demonstration of the site’s emergency arrangements and their capability to deal with a nuclear and radiological emergency on site.  In accordance with ONR’s arrangements, a letter will be forwarded to site in due course with our formal assessment and feedback on those areas where the site performed well and those areas identified for improvement.   

Conclusion of Intervention

Overall, we consider that the arrangements and their associated implementation for LC7, LC8, LC9 and IRR17 for the areas inspected met with the required standards.  Additionally, we consider that the annual site Level 1 Demonstration emergency exercise provided an adequate demonstration of the site’s emergency arrangements against the requirements of LC11. We did not identify any matter impacting on nuclear safety that required any further immediate regulatory action.