Office for Nuclear Regulation

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Dounreay - LC compliance inspections - LC12, LC26 and LC28

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:

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, specifically:

The LC28 inspection also provided the opportunity to assess the examination, inspection, maintenance and testing arrangements in place to support nuclear safety significant ventilation systems across site.

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A

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

The LC12 and LC26 compliance inspections were undertaken in parallel and focused on the competence and assessments associated with the project supervisors’ role and their duties with regards the control and supervision of activities within the following areas across site:

We examined the corporate level competencies set against the project supervisor role and the associated safety competencies defined in company procedures. We noted the proposal to include a requirement for all project supervisors working in radiological areas to have completed training and formal assessment as a Radiation Protection Supervisor (RPS0. We also noted the review ongoing to assess the supervisor training provided by the construction industry training board (CITB) to enhance the current DSRL arrangements.

From our examination of the arrangements in place within each of the operational areas it was clear that Authority to Operate (ATO) holders required facility specific competencies to be met over and above the corporate competencies set for their project supervisors.  

During our plant visits in each of the operational areas we observed a variety of tasks being performed ranging from high hazard to relatively low.  In all cases we observed that there was clarity in understanding regarding the hazards associated with the task and that the supervisor was clearly in control of the work going on.  Each supervisor we engaged with was able to demonstrate their understanding of their responsibilities and legal obligations as supervisors and demonstrated the arrangements in place by which they could exercise the necessary control and supervision of tasks.

 In addition we examined the implementation of the corporate arrangements for LC12 in support of DSRL’s emergency arrangements.  We noted that each role that makes up the emergency response capability is supported by a corresponding competency definition document (CDD) and that the emergency response team conduct all training against those competencies and undertake the associated assessment. We discussed how feedback from exercises is used to review and improve the training provided noting the work ongoing to improve security awareness for key roles within the emergency control centres.  We examined the different approaches applied for the formal assessment of competencies from formal written examinations to carrying out the role during an exercise. 

Overall we are satisfied that those arrangements examined and, their implementation within those areas inspected, demonstrate compliance against the requirements of LC12 and LC26.

For LC28 we examined the implementation of the corporate arrangements in the following areas:

 The inspection of maintenance of the nuclear safety significant ventilation systems was conducted in response to concerns raised previously by SEPA regarding the periodic replacement of HEPA filters in accordance with the schedule defined in DSRL’s corporate level standard.  From our discussions with DSRL managers we are satisfied that DSRL’s arrangements under LC28 provide adequate assurance regarding the performance of nuclear safety significance ventilation systems.  We also noted the improvement plan in place to address SEPA’s concerns.

We examined the current arrangements by which DSRL is assured that all structures, systems and equipment necessary for the provision of an adequate emergency response capability remain fit for purpose.  From our examination of the testing and maintenance records of a sample of key equipment that support the site’s emergency arrangements we are satisfied that adequate arrangements are in place by which DSRL can demonstrate the continued performance of its provisions to ensure an adequate response to a site emergency.

 Overall we are satisfied that DSRL has demonstrated the adequate implementation of its arrangements made under LC28 in support of those areas inspected.   

Conclusion of Intervention

Overall, we consider that the arrangements and their associated implementation for LC12, LC26 and LC28 for the areas inspected met with the required standards.  We did not identify any matter impacting on nuclear safety that required any further immediate regulatory action.