Office for Nuclear Regulation

Readiness Review of Restart of Operations and Conventional Health & Safety and CDM

Executive summary

Purpose of Intervention

The purpose of this inspection was to assess Dounreay Site Restoration Limited (DSRL) site’s arrangements for the restart of operational activities as part of the return from Covid-19 lockdown.  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 recommencement 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 intervention also provided the opportunity to undertake a compliance inspection of the implementation of DSRL’s arrangements for Conventional Health & Safety [Lifting operations] in support of the DCP Stores Extension Construction Project.

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A

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

Within DFR/BFR and DMTR we assessed the arrangements in place to secure the continued protection of personnel in the conduct of their operational tasks; we assessed the arrangements for ensuring that engineered safety systems and plant were fit for purpose and in a suitable state to support the recommencement of operational activities.  We 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.  We 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.

We also observed activities that had recently recommenced focusing on the implementation of revisions due to Covid-19 and revised plant status.  We are satisfied, based on these observations, that the level of control and supervision observed supports the safe recommencement of operations following a period of prolonged plant shut down.  

Overall, within the operational areas inspected, we are satisfied that there was clear evidence of a structured and systematic approach to the safe recommencement 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 we are satisfied that the management associated with the recommencement of operations has been systematic and transparent.  On that basis we judge that DSRL remains compliant with the requirements of LC8, LC9, LC12, LC24, LC26 and LC28.

We 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 recommencement of operations.  There is clear evidence that IAT continues to play a key role in the verification of the evidence supporting the recommencement of operations.

We undertook an inspection of the DCP stores extension site to determine the adequacy of the arrangements for the management of lifting operations.  We evaluated the relevant arrangements including planning, supervision and carrying out of lifting operations.  We discussed roles and responsibilities for lifting operations with the site manager and training and competence with the lifting team.  We observed a pre-job brief, where the site appointed person for lifting discussed the method statement with the lifting team.  We also observed a lifting operation involving the crawler crane. We discussed progress with the lifting improvement plan, developed by DSRL with Graham Construction Ltd (GCL).

Based on the evidence gleaned, we are satisfied that the revised arrangements for the management of lifting operations on the DCP stores extension site are adequate and demonstrate compliance with Regulation 8 of the Lifting Operations and Lifting Equipment Regulations (LOLER).  In addition, DSRL has made substantial progress with the site wide lifting operation improvement plan.      

Conclusion of Intervention

We consider that the arrangements and their associated implementation for the restart of operations in the areas inspected met with the required standards.  We also consider that the revised arrangements for the management of lifting operations on the DCP stores extension site are adequate and demonstrate compliance with Regulation 8 of LOLER. We did not identify any matter impacting on nuclear safety that required any regulatory action.