Office for Nuclear Regulation

Dounreay - Readiness Review of Return of Staff to Site and the Restart of Operations

Executive summary

Purpose of Intervention

The purpose of this inspection at Dounreay Site Restoration Limited (DSRL) was mainly to assess the site’s arrangements for the safe return of staff to site and for the restart of operational activities.  These inspections are being conducted in accordance with the 2020/21 Integrated Intervention Strategy (IIS) to confirm that the licensee is controlling its hazards and complying with its statutory obligations.

Interventions Carried Out by ONR

ONR undertook inspections of the site’s arrangements and their implementation for the safe return of staff to site following the easing of Covid-19 ‘lock-down’ restrictions in the following areas:

ONR also undertook inspections of the site’s arrangements and their implementation for the restart of operational activities within the following areas:

Where it has been judged appropriate to do so, ONR has assessed those activities against the requirements of the following Licence Conditions (LCs):

This inspection also provided the opportunity to review the activities of DSRL’s independent assurance team in support of the governance of the development and implementation of the above arrangements.

During this intervention, ONR held a meeting with the site safety representatives.

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A

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

I assessed the arrangements in place for the safe return of staff to the general site areas. I am satisfied that DSRL has implemented adequate arrangements within the general site areas, specifically work areas, corridors and ‘service points’ (work control centres), to meet the guidelines set out by UK and Scottish Government and to meet their legislative duty under the Health and Safety at Work etc Act 1974.  These arrangements have been supported by an effective communications plan comprising ‘social media, an App, videos, teleconferences and familiarisation visits to provide staff with the information necessary to support their return to site.  Return to work is also controlled via a series of checklists to ensure personnel receive the necessary briefings and other additional training required to support their return to work. 

In addition I assessed the arrangements specific to the return of personnel into radiological controlled areas.  I am satisfied that DSRL has implemented a considered and pragmatic approach that balances the need to provide the necessary assurances regarding radiological contamination against the potential for cross-contamination of Covid-19.

I am also satisfied that, despite the nature of the Covid-19 threat and the changes in guidance as government policy evolves, DSRL’s management of their response to the Cov-19 requirement, specifically management of warning notices, instructions to persons on site and training, have been conducted in accordance with their extant arrangements. Based on the evidence examined, I am satisfied that DSRL remains compliant with the requirements of L8, LC9 and LC10.

I also assessed the site’s emergency arrangements covering the transition from a quiescent state through to the restart of operations.  I am satisfied that DSRL has an adequate justification for providing an emergency response capability based upon the site’s current ‘out of hours’ arrangements; DSRL have also provided clear evidence that this position remains under continual review as additional operational activities are scheduled to recommence. Based on the evidence inspected I am satisfied that DSRL remains compliant with the requirements and regulatory expectations for LC11.

I assessed the arrangements in place for the restart of operational activities within the Reactors and the FCA Decommissioning Operational Areas, specifically PFR, DFR and D2001.

Within each of the areas I assessed the arrangements in place to secure the continued protection of personnel in the conduct of their operational tasks; I assessed the arrangements for ensuring that engineered safety systems and plant were fit for purpose and in a suitable state to support the restart of operational activities.  I assessed the arrangements by which the limits and controls for safe operations were reviewed to account for changes in restrictions or system status and, the revisions as appropriate to extant operating instructions.  I also assessed the arrangements by which operator SQEP was assured, in particular addressing the potential for skill fade during a prolonged period away from plant operations.

I also took the opportunity to observe activities that had recently recommenced focusing on the implementation of revisions due to Covid-19 and revised plant status.  I am satisfied, based on these observations, that the level of control and supervision witnessed supports the safe restart of operations following a period of prolonged plant shut down.  

Overall, within the operational areas inspected, I am satisfied that there was clear evidence of a systematic approach to the safe restart of operations. The arrangements in place demonstrated a considered review of the status of the plant, the competency and currency of the personnel and, the suitability of the operating documentation.  Additionally I am satisfied that the governance associated with the restart of operations has been robust and transparent.  On that basis I judge that DSRL remains compliant with the requirements and regulatory expectations of L12, LC24, LC26, LC28 and LC36.

I reviewed the activities undertaken by the DSRL Independent Assessment Team (IAT) in support of the development, implementation and governance of the site’s arrangements for the safe return of staff to site and the restart of operations.  There is clear evidence that IAT has played a key role in the independent assessment of the development and implementation of these arrangements; there is also clear evidence that the advice provided by IAT has been a key contribution to the decisions made by the DSRL executive team in transitioning from quiescence to preparation to remobilisation.  I also observed the key role IAT provides in the verification of the evidence supporting the restart of operations.

Overall, ONR is satisfied that DSRL continues to demonstrate adequate control and supervision of its activities. 

Conclusion of Intervention

I consider that the arrangements and their associated implementation for the safe return of staff to site and for the restart of operations in the areas inspected met with the required standards.  I did not identify any matter impacting on nuclear safety that required any further regulatory action.