Office for Nuclear Regulation

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CDM compliance inspection, assessment of Infrastructure Lifetime Plans and Conventional Health and Safety

Executive summary

Purpose of Intervention

This was one of a series of planned inspection activities at Dounreay Site Restoration Limited (DSRL) in accordance with the 2019/20 Integrated Intervention Strategy (IIS) to confirm that the licensee is controlling its hazards and complying with its statutory obligations.

Interventions Carried Out by ONR

The following inspections activities were undertaken:

The assessment of Infrastructure Lifetime Plans covered the corporate arrangements and their implementation within the following areas on site:

The inspection against CDM covered the corporate arrangements and their implementation in support of the Dounreay Material Test Reactor (DMTR) Decommissioning Project.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable.

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

The joint Civil Engineering & External Hazards and Conventional Health & Safety inspection focused on the procedures and processes for the inspection and maintenance of civil structures as required under LC28 [Examination, inspection, maintenance and testing], along with the site’s lifetime plan and associated asset management framework as required by LC35 [Decommissioning].  It also included an examination of DRSL’s arrangements for the management of conventional health and safety risks associated with the inspection and maintenance of ageing infrastructure. The inspection also comprised a number of plant walk-downs to examine the implementation of the corporate arrangements on site.

In summary we are satisfied that DSRL has adequate arrangements in place for the management of infrastructure across site and there is clear evidence of the effective implementation of those arrangements particularly in support of business critical facilities. Where structural degradation has become more significant DSRL will need to consider how subsequent substantiations will be made, in particular the point at which quantitative analysis will be required to account for section loss and material degradation rates. We are also satisfied that DSRL has adequate arrangements for the management of Conventional Health and Safety risks: advice was given to DSRL to address access to fragile areas on facility roofs.

The CDM inspection focused on the application of the CDM regulations to the DMTR project, specifically the appointment of client, principal designer and principal contractor and examined the arrangements for managing safety in the pre-construction phase.

Overall we are satisfied that DSRL has adequate arrangements to meet the requirements of the CDM regulations. We are also consider that the implementation of their CDM arrangements in support of the DMTR decommissioning project to be adequate and consider the rationale for keeping the CDM appointees in-house to be reasonable given the project’s current status.  We also acknowledged DRSL’s on-going review and revision of their CDM arrangements to reflect the changing risk profile of the site.

Conclusion of Intervention

Overall, we consider that DSRL has adequate arrangements in place for the management of business critical and ageing infrastructure and for the management of the conventional health and safety risks associated with those activities.  We also consider that DSRL has adequate arrangements in place for the management of CDM in support of the DMTR decommissioning project.  We did not identify any matter impacting on nuclear safety that required any further immediate regulatory action.