Office for Nuclear Regulation

Dounreay - LC Compliance inspections and the Annual Review of Safety and Security

Executive summary

Purpose of Intervention

The purpose of this intervention was to attend the Annual Review of Safety and Security and to undertake Licence Condition (LC) compliance inspections 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

The primary purpose of this intervention was to attend DSRL’s Annual Review of Safety and Security (AROSS). This review covers the assessment of their safety and security performance for 2018/19 and their presents their focus for 2019/20.

This intervention also included an inspection of the site’s arrangements made under IIR17 and the following LCs:

The AROSS was presented to the ONR Superintending Inspector [Nuclear Safety], the ONR Superintending Inspector [Nuclear Security], the ONR Dounreay site safety inspectors and the ONR Dounreay site security inspectors.  The LC compliance inspections were undertaken by the Dounreay site safety inspectors.

This intervention also provided the opportunity to review progress against the implementation plan for the proposed management of change of their executive and associated directorate structure.

We also attended the Dounreay Site Stakeholder Public Meeting held on 13 Mar 19.

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A

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

The overall picture presented by the Site in support of the ARoSS was one of a good performance with some areas identified for improvement, ONR largely concurred with this summary.  Hazard and risk reduction continues at a steady pace as the focus remains on material consolidation.  There is clear professionalism and commitment from the management team to setting high standards and to reinforce these with all staff.

The subsequent plant visits to the FCA and DFR provided the opportunity to observe and discuss the work ongoing in these areas. It was clear that the operators involved in the decommissioning work in these areas are very enthusiastic and committed to high safety standards; the control and supervision and housekeeping conditions are generally good.

Overall, we considered the ARoSS presented by DSRL to be consistent with ONR’s current view and to provide a good basis on which to develop improvements in safety and security performance.

The LC7 compliance inspection followed on from those areas discussed at the previous inspection of 11-13 Sep 18 [ONR-SDFW-IR-18-099 refers].  There is clear evidence that DSRL has made significant progress in their understanding of the issues discussed to date and are now better placed to drive forward the improvements they wish to make to their current arrangements.  We will continue to monitor progress of this improvement activity through our schedule of LC7 compliance inspections. DSRL has also strengthened their arrangements in a number of other areas; these have resulted in tangible improvements in safety performance within specific, targeted topic areas.

Overall we are satisfied that DSRL’s arrangements for LC7 demonstrate compliance against the legal requirements specified within the licence conditions and the regulatory expectations enshrined within ONR’s guidance. In addition we also consider that adequate progress is being made in those aspects of the site’s arrangements for LC7 where we have agreed there to be areas for improvement.

The inspection against LC11 focused on the corporate arrangements and the implementation of those arrangements that support the requirements defined against Topic Area 2 [ANTICIPATE] of the Dounreay On-Site Emergency Preparedness and Response (EP&R) Capability Map [Original assessment undertaken Jul 15]. TRIM Reference: 2015/273551].  The site continues to provide a comprehensive suite of evidence that provides an adequate demonstration of the expectations set out against the various aspects covered by Topic Area 2 and demonstrated their process for reviewing those arrangements against a changing hazard profile and learning from operational experience.

Overall I considered that each of the four aspects covered within Topic Area 2 of the Dounreay on-site EP&R capability map merited a regulatory rating of 1 [all nuclear safety requirements met]: This also provided a clear demonstration of their compliance against the requirements of LC11 for those areas covered by Topic Area 2.   

Conclusion of Intervention

Overall, we consider the ARoSS provided by DSRL to be an adequate representation of their safety and security performance for 2018/19 and to provide the basis of improvements in their performance for 2019/20.  We also consider that the arrangements and their associated implementation for LC7 and LC11in 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.