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Dounreay - Inspection ID: 50591

Executive summary

Date(s) of inspection:

  • July 2022

Aim of inspection

The Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19) require in Regulation 6 that operators “maintain a system of accountancy and control” and that the components of this system must be implemented “in a manner which is proportionate to and appropriate for the basic technical characteristics of the qualifying nuclear facility”. ONR nuclear safeguards inspectors will conduct an accountancy compliance inspection of Dounreay Site Restoration Ltd. (DSRL), focussing on the facilities involved in the accountancy and control of qualifying nuclear material (QNM) in the form of retained waste in Material Balance Area (MBA) QDR6 (including D9867, D1208, D8570 and D2700). The inspection will also examine the accountancy of low-level discharges of QNM to the Environment. The inspection shall commence on Tuesday 12 July 2022. The purpose of an accountancy focused inspection is to provide assurance to ONR that the operator is adequately implementing their arrangements for nuclear material accountancy and control of qualifying nuclear material (QNM). This includes maintaining adequate operating records and accounting records, which are traceable to the accounting reports provided to the ONR and are underpinned by suitable accountancy arrangements.

This inspection seeks evidence in support of DSRL’s compliance with The Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19). ONR will form regulatory judgements and provide a rating in line with ONR’s inspection rating guidance of DSRL’s compliance against the following Regulations in NSR19:
  • Regulation 6(3): Accountancy and Control of Qualifying Nuclear Material.
  • Regulation 9(1): Operation of an Accountancy and Control Plan (ACP)
  • Regulation 29(1): Stock list and accounting records for conditioned and retained waste

Subject(s) of inspection

  • NSR19 Reg06 - Accountancy and control of qualifying nuclear material - Rating: Green
  • NSR19 Reg09 - Operation of an accountancy and control plan - Rating: Green
  • NSR19 Reg29 - Stock list and accounting records for conditioned and retained waste - Rating: Green

Key findings, inspector's opinions and reasons for judgement made

This inspection was one of a programme of planned inspections at Dounreay Site Restoration Ltd. (DSRL) during 2022/2023, developed in accordance with the Safeguards Sub-Division Strategy. This inspection was an accountancy focussed inspection of operator arrangements against The Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19).

ONR nuclear safeguards inspectors and I conducted an accountancy compliance inspection of Dounreay Site Restoration Ltd. (DSRL), focussing on the facilities involved in the accountancy and control of qualifying nuclear material (QNM) in the form of retained waste in Material Balance Area (MBA) QDR6 (including D9867, D1208, D2700, and D8570). The inspection also examined the accountancy of low-level discharges of QNM to the Environment.  This inspection sought to collect evidence of arrangements and their implementation to make judgements of compliance against NSR19 Regulations 6(3), 9(1) and 29(1). The inspection comprised of discussions with staff, reviews of operating and accounting records, and a plant walkdowns for sampled plants within the QDR6 MBA.

The inspection targeted the operating and accounting records underpinning reported inventories of QNM in the form of retained waste, transactions of QNM to/from retained waste, and transfers of QNM to the environment. I sought assurance that transactions were underpinned by appropriate source documents generated by the adequate implementation of relevant arrangements and procedures for nuclear material accountancy and control (NMAC). I also sought assurance that those arrangements and procedures align with arguments made in relevant Accountancy and Control Plans (ACPs)

This intervention was performed in line with ONR's guidance (as described in the relevant technical inspection guides, which can be found on ONR’s website (onr.org.uk).

No significant shortfalls in compliance against NSR19 were identified during this intervention.
The maintenance of retained waste stock lists
On the basis of the stock list and source documentation sampled, I am satisfied that DSRL are adequately implementing arrangements to maintain and update a retained waste stock list and adequate source documentation to determine changes in the quantities and composition of retained waste. I am satisfied that DSRL are complying with the requirements of NSR19 regulations 29(1)(a) and 29(1)(b) in this regard. I am satisfied that their records of retained waste include all changes to the stock of retained waste, so that the book inventory of retained waste can be established when requested, in line with NSR19 regulation 29(1)(e). In explaining those changes to the stock of retained waste, DSRL identified a minor mistake in the reported quantities of HEU transferred to retained waste. I consider this a minor shortfall against regulation 12(2) and advised DSRL that they must correct this mistake at the next opportunity. On the basis of the source documentation presented to me throughout the course of the inspection for the sampled items, I am satisfied that the retained waste stock list correctly records the sampled items of retained waste.

The accountancy and control of retained waste 
Based on the arrangements and source documentation sampled, I judge that DSRL are implementing adequate arrangements to track retained waste in D1208, D2700, and D9867 in line with MACE 7.1. I am also satisfied that these arrangements align with arguments made in accountancy and control plans for those facilities, in compliance with regulation 9.1. The source documentation substantiated the accountancy records for the sampled items

The reporting of terminations to the environment
I am satisfied that DSRL are implementing adequate arrangements to account for the termination of nuclear material within their retained waste account, and that termination can be substantiated through adequate source documentation - in compliance with regulation 29(1)(b). I am also satisfied that DSRL are implementing adequate arrangements to report those terminations in compliance with Part 2 of Schedule 1 of NSR19.

Conclusion

On the basis of the arrangements and source documentation presented to me during the course of the inspection (including completed Operating Instructions, Quality Plan records, NDA results, and ATOM records) I am satisfied that DSRL are implementing adequate arrangements to track retained waste in D1208, D2700, and D9867 - in line with MACE 7.1. I am also satisfied that these arrangements align with arguments made in accountancy and control plans for those facilities, in compliance with regulation 9.1. The source documentation presented to me substantiates the accountancy records for the sampled items and I am satisfied that those records are correct and can be substantiated by adequate authorised source documentation.

I am satisfied that DSRL are implementing adequate arrangements to account for the termination of nuclear material within their retained waste account, and that termination can be substantiated through adequate source documentation - in compliance with regulation 29(1)(b). I am also satisfied that DSRL are implementing adequate arrangements to report those terminations in compliance with Part 2 of Schedule 1 of NSR19.I noted that DSRL does not assign a particular obligation code to reported terminations to the environment, as stipulated by NSR19 regulation 19. I advised that when nuclear material is consigned to retained waste it does so with a particular obligation code, and DSRL therefore maintains an inventory of particular obligations on that account. I advised DSRL that if no terminations are assigned a particular obligation code, they will eventually exhaust their unobligated inventory in retained waste and will be forced to assign particular obligations to those terminations. I also advised DSRL that Annex IV of the BEIS-ONR NCA Implementation Guidelines for Nuclear Operators expects that the Principle of Proportionality should be applied to process discards and operating losses of any processing of obligated nuclear material, including any discards to the environment. 

On the basis of the stock list and source documentation presented to me for the sampled items above I am satisfied that DSRL are adequately implementing arrangements to maintain and update a retained waste stock list, and adequate source documentation to determine changes in the quantities and composition of retained waste. I am satisfied that DSRL are complying with the requirements of NSR19 regulations 29(1)(a) and 29(1)(b) in this regard. I am satisfied that their records of retained waste include all changes to the stock of retained waste, so that the book inventory of retained waste can be established when requested, in line with NSR19 regulation 29(1)(e). On the basis of the source documentation presented to me throughout the course of the inspection for the sampled items, I am satisfied that the retained waste stock list correctly records the sampled items of retained waste.

I consider the minor mistake in reported quantities of HEU transferred to retained waste to be a minor shortfall against regulation 12(2) and advised DSRL that they must correct this mistake in the next Inventory Change Report (ICR).

I advised DSRL that ONR shall continue to apply regulatory attention to DSRL's retained waste account and that DSRL must be able to identify any changes to that account that are not formally reported to ONR through NSR19 regulation 14, and present adequate source documentation to substantiate those changes in compliance with NSR19 regulation 29(1)(b). I also advised that regulation 4(1) of NSR19 requires DSRL to submit a Programme of Activities according to Part 8 of Schedule 1, which includes a requirement for information on planned waste processing. I advised DSRL that such Programmes of Activities should highlight any anticipated or possible changes to the quantity of retained waste resulting from such processing that shall not be formally reported to ONR through NSR19 regulation 14.I observed that the ad-hoc balance report of the retained waste account provided by DSRL is a good practice mechanism to identify changes to the retained waste account that are not formally reported to ONR through NSR19 regulation 14.

Based on the sample inspected during the intervention I judge that DSRL is compliant with the requirements of regulations 6(1), 9(1) and 29(1) in the areas sampled, noting a minor shortfall against regulation 12 (2) relating to the accuracy of historic accountancy reports. I provided regulatory advice regarding the correction of historic reporting accuracies and this shortfall shall be remedied through the next Inventory Change Report (ICR). No significant shortfalls in compliance against NSR19 were identified during this intervention.