Executive summary
Date(s) of inspection:
- November 2022
Aim of inspection
ONR nuclear safeguards inspectors are scheduled to visit the Dounreay site on 8th November 2022 for the purpose of conducting an Accountancy-Focussed Compliance Inspection for material balance areas (MBAs) QDR4 and QDR5, and an Accountancy and Control Plan (ACP) Compliance Inspection focussing on the ATOM accountancy system. The intervention will adopt a sampling approach to seek evidence in support of 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 – Accountancy and control of qualifying nuclear material
- Regulation 9(1) – Implementation of arrangements within an ACP
- Regulation 11(2) – Accounting records
- Regulation 14 – Inventory Change Report
- Regulation 15 – Material balance report and physical inventory listing
Subject(s) of inspection
- FSE 3 Competence Management - Rating: Green
- FSE 5 Reliability, Resilience and Sustainability - Rating: Green
- FSE 7 Nuclear Material Tracking - 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).
The supporting inspector and I conducted a combined accountancy and Accountancy and Control Plan (ACP) compliance inspection of Dounreay Site Restoration Ltd. (DSRL).
I am satisfied that qualifying nuclear material is being adequately recorded and reported in QDR4 and QDR5, and that it is being tracked in line with my expectations of FSE 7. I rate this aspect of the inspection green.
I found evidence that DSRL’s arrangements for maintaining and recording the calibration of NDA equipment were not being adequately implemented and consider this a shortfall against ONR’s expectations regarding Measurement Control Programmes (MACE 6.1). I am satisfied that DSRL have since addressed this shortfall and I shall not raise a regulatory issue to track any further action in this regard.
I am satisfied that ATOM editors and ATOM administrators are suitably qualified and experienced. I am satisfied that the arrangements put in place by the NMA and the NMC meet ONR’s expectations regarding Competence Management (FSE 3) but the ATOM editor arrangements are not being implemented within DSRL’s site-wide framework for competence management described in PRC-0011. I consider this a minor shortfall against DSRL’s own arrangements, and I rate this aspect of the inspection green. I have expanded an existing regulatory issue to monitor DSRL’s actions to bring ATOM editor training within the framework of PRC-0011.
I am satisfied that DSRL are implementing adequate arrangements for the Examination, Maintenance, Inspection, and Testing (EIMT) of the ATOM system, in line with ONR’s expectations in that regarding (MACE 5.2). However, I consider the current reliance on End of Life (EoL) operating systems to be a shortfall against ONR’s expectations regarding reliability, resilience, and sustainability (MACE 5.1 and 5.3). This shortfall presents a significant risk to the sustainability of ATOM, but DSRL have proactively identified the risk and have a detailed Work Improvement Plan (WIP) in place to address it. Thanks to these proactive actions to address a significant risk, I consider this aspect of the inspection green and will raise a Level 4 regulatory issue to track the delivery of the WIP.
Conclusion
From the evidence sampled I am satisfied that qualifying nuclear material is being adequately recorded and reported in QDR4 and QDR5, and that it is being tracked in line with my expectations of FSE 7. I rate this aspect of the inspection green.
I found evidence that DSRL’s arrangements for maintaining and recording the calibration of NDA equipment were not being adequately implemented and consider this a shortfall against ONR’s expectations regarding Measurement Control Programmes (MACE 6.1). I am satisfied that DSRL have since addressed this shortfall and I shall not raise a regulatory issue to track any further action in this regard.
From the evidence sampled, I am satisfied that ATOM editors and ATOM administrators are suitably qualified and experienced. I am satisfied that the arrangements put in place by the NMA and the NMC meet ONR’s expectations regarding Competence Management (FSE 3) but these arrangements are not being implemented within DSRL’s site-wide framework for competence management described in PRC-0011. I consider this a minor shortfall and will expand the scope of an existing level 3 regulatory issue to monitor the integration of these arrangements into PRC-0011. I rate this aspect of the inspection green.
From the evidence sampled, I am satisfied that DSRL are implementing adequate arrangements for the Examination, Maintenance, Inspection, and Testing (EIMT) of the ATOM system, in line with ONR’s expectations in that regarding (MACE 5.2). However, I consider the current reliance on End of Life operating systems to be a minor shortfall against ONR’s expectations regarding reliability, resilience, and sustainability (MACE 5.1 and 5.3). I am seeking improvement from DSRL, which will be delivered through a Work Improvement Programme (WIP) that has been formalised in the DSRL Site Security Plan. I rate this aspect of the inspection green and I shall raise a new level 4 regulatory issue to monitor the progress of the WIP.
I found evidence that DSRL’s arrangements for maintaining and recording the calibration of NDA equipment were not being adequately implemented and consider this a shortfall against ONR’s expectations regarding Measurement Control Programmes (MACE 6.1). I am satisfied that DSRL have since addressed this shortfall and I shall not raise a regulatory issue to track any further action in this regard.
From the evidence sampled, I am satisfied that ATOM editors and ATOM administrators are suitably qualified and experienced. I am satisfied that the arrangements put in place by the NMA and the NMC meet ONR’s expectations regarding Competence Management (FSE 3) but these arrangements are not being implemented within DSRL’s site-wide framework for competence management described in PRC-0011. I consider this a minor shortfall and will expand the scope of an existing level 3 regulatory issue to monitor the integration of these arrangements into PRC-0011. I rate this aspect of the inspection green.
From the evidence sampled, I am satisfied that DSRL are implementing adequate arrangements for the Examination, Maintenance, Inspection, and Testing (EIMT) of the ATOM system, in line with ONR’s expectations in that regarding (MACE 5.2). However, I consider the current reliance on End of Life operating systems to be a minor shortfall against ONR’s expectations regarding reliability, resilience, and sustainability (MACE 5.1 and 5.3). I am seeking improvement from DSRL, which will be delivered through a Work Improvement Programme (WIP) that has been formalised in the DSRL Site Security Plan. I rate this aspect of the inspection green and I shall raise a new level 4 regulatory issue to monitor the progress of the WIP.