Office for Nuclear Regulation

Dounreay - LC Compliance Inspections [LC7, LC26] and the Annual Review of Safety and Security

Executive summary

Purpose of Intervention

The purpose of this inspection was to undertake Licence Condition (LC) compliance inspections 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.  In addition the Annual Review of Safety and Security was held.

Interventions Carried Out by ONR

DSRL’s Annual Review of Safety and Security (ARoSS) covers an assessment of their safety and security performance for 2019/20 and presents their focus for 2020/21.

ONR also undertook inspections of the site’s arrangements and their implementation against the requirements of the following LCs:

We also attended the Public meeting of the Dounreay Site Stakeholder Group.

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A

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

The ARoSS presented by DSRL provided an open and balanced reflection of the site’s safety and security performance during 2019/20 whilst acknowledging the difficulties it has had to contend with during this period.  The site was commended by ONR for the safe and secure delivery of the material consolidation programme whilst maintaining progress on a number of other key hazard reduction activities across the site.  DSRL also acknowledged their aim to improve safety and security performance in a number of areas with a focus on improved culture, control and supervision of high hazard construction and industrial safety activities and, improved resilience of their organisational capability.  DSRL focus is to continue with the hazard reduction and decommissioning activities to deliver the agreed interim end -state.

The plant walk-downs in the FCA and PFR prior to the ARoSS 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 enthusiastic and committed to high safety standards; the control and supervision of operations and general housekeeping within those facilities are of good standard. It is also evident that the management teams in those areas demonstrate a clear professionalism and commitment to engage with their teams, setting high standards providing continual reinforcement of these standards with all their staff.

The LC7 compliance inspection provided the opportunity to follow up on progress against the improvement areas reported on previous LC7 inspections.  It is clear that DSRL continues to improve their understanding of the issues discussed to date and have implemented a number of arrangements that have successfully addressed a number of specific topic areas.  DSRL is now looking to further their understanding of the underlying cultural factors associated with event reporting and learning from experience and will be presenting the outcome of their considerations to ONR during a subsequent inspection. Overall we are satisfied that DSRL’s arrangements for LC7 are adequate.

The inspection against LC26 focused on the two areas visited prior to the ARoSS [PFR and D1204] and additionally DFR and D1208. The assessment made against this LC also drew upon ONR’s observations during each of the plant visits undertaken as part of the continuing theme of LC26 inspections conducted throughout ONR’s schedule of inspections during 2019/20; the results of these plant visits were recorded within the inspection records covering those individual inspections. Overall, ONR is satisfied that DSRL continues to demonstrate adequate control and supervision of its activities. 

Conclusion of Intervention

During the ARoSS DSRL personnel provided an open and honest representation of their safety and security performance for 2019/20 and to provide the basis of improvements in their performance for 2020/21.  We also consider that the arrangements and their associated implementation for LC7 and LC26 in 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.