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.
This intervention included an inspection of the site’s arrangements made under the following LCs:
The inspections were undertaken by an ONR Dounreay site inspector and were based on examining a sample of the licensee’s arrangements and their implementation on site. For LC14 and LC15 the inspections covered the implementation of those arrangements with regards to:
For LC22, the inspections focussed on the implementation of those arrangements in support of the following projects:
This intervention also provided the opportunity to attend the Site Restoration Sub-Group meeting of the Dounreay Stakeholder Group.
For the LC14 and LC15 compliance inspections I focused on those activities supporting DSRL’s internal assessment of safety documentation, specifically:
I examined those elements of the management system that applied to the development, categorisation, periodic review and independent assessment of safety submissions at DSRL. Overall I am satisfied that those arrangements sampled demonstrate compliance against the legal requirements specified within the licence conditions and the regulatory expectations enshrined within ONR’s guidance.
I also examined the implementation of the site’s arrangements for the assessment activities supporting the development and periodic review of safety submissions. There was evidence of robust challenge provided throughout the development of safety submissions with clear evidence of appropriate advice being provided to those with the accountability for authorising nuclear and radiological safety related operations. Additionally, DSRL demonstrated that personnel with safety documentation development, management, or assessment roles were suitably qualified and experienced; where contracted personnel were utilised DSRL could demonstrated an adequate intelligent customer capability. .
Overall I am satisfied that DSRL has implemented adequate arrangements to assess the suitability and sufficiency of safety documentation submitted in support of nuclear and radiological safety related operations on site against the expectations enshrined within ONR’s guidance. An examination of the site’s administration of the minutes resulting from meetings of the DNSEC did not meet the specific requirement of LC13(8) [Nuclear safety committee] to send to ONR within 14 days of any meeting of the DNSEC a full and accurate record of all matters discussed at that meeting, including in particular any advice given to the licensee. A regulatory issue has been raised to monitor DSRL’s resolution of this matter.
For the LC22 inspection I focused on the implementation of the corporate arrangements in support of the following projects on site:
I examined those elements of the management system related to the control of modifications undertaken in existing plant. I confirmed that these arrangements aligned with those other aspects of the management system relating to safety submission development and commissioning as appropriate and that there were adequate arrangements to ensure the categorisation applied also considered the aggregation of modifications being undertaken on a system basis. Overall I am satisfied that those arrangements sampled demonstrate compliance against the legal requirements specified within the licence conditions and the regulatory expectations enshrined within ONR’s guidance.
I also examined the implementation of those arrangements in support of the East Ponds Project within DFR and the ADU Floc Project within D1208. I reviewed the safety justifications in place to support both projects and am satisfied that they provided the necessary basis for the classification applied. The accountabilities were well established with the ATO Holder retaining control over all operations conducted within their area of accountability. Personnel associated with the delivery and control of the projects were demonstrated to be suitably qualified and experienced with clear evidence that DSRL could demonstrate the necessary intelligent customer capability where contracted personnel were utilised. There was also a clear demonstration of the effective use of suitable hold-points identified within the controlling documents (DMRs) ensuring that the ATO Holder retained control at key stages of the project. Within D1208, the project involves a number of inter-related modification activities; I confirmed that the DMRs associated with those activities identified those interdependencies and the basis against which individual stages of each DMR could proceed.
Overall I am satisfied that DSRL has demonstrated the adequate implementation of their arrangements for LC22 in support of those areas inspected against the expectations enshrined within ONR’s guidance.
Overall, I consider that the arrangements and their associated implementation for LC14, LC15 and LC22 for the areas inspected met with the required standards. A minor shortfall was identified with the administrative arrangements supporting a related licence condition (LC13) for which a regulatory issue has been raised. I did not identify any matter impacting on nuclear safety that required any further immediate regulatory action.