Executive summary
Date(s) of inspection
- November 2023
Aim of inspection
ONR nuclear safeguards inspectors conducted a nuclear material accountancy focussed compliance inspection of the Dounreay facilities; DN029, D3110, DN016, as well as any facilities deemed relevant to the inspection, The purpose of this inspection was to seek evidence in support of Dounreay’s compliance with The Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19).
ONR formed regulatory judgements and provided a rating in line with ONR’s inspection rating guidance of Dounreay’s compliance against the following Regulations in NSR19 Regulations 6, 7, 9, 12, 15, 19, 29.
To form effective regulatory judgements on Dounreay’s compliance with the NSR19 regulations listed above, inspectors considered the ONR Guidance for the Assessment of Nuclear Material Accountancy, Control and Safeguards (ONMACS) guidance and the expectations within. There was a particular focus on FSE’s 7 and 8.
Subject(s) of inspection
- FSE 7 Nuclear Material Tracking – Rating: Green
- FSE 8 Data Processing and Control – Rating: Green
- NSR19 Reg06 – Accountancy and control of qualifying nuclear material – Rating: Green
- NSR19 Reg07 – Accountancy and control plan – Rating: Green
- NSR19 Reg09 – Operation of an accountancy and control plan – Rating: Green
- NSR19 Reg12 – Accounting reports – Rating: Green
- NSR19 Reg15 – Material balance report and physical inventory listing – Rating: Green
- NSR19 Reg19 Additional reporting obligations arising from relevant international agreements and from obligations resulting – Rating: Green
- NSR19 Reg29 – Stock list and accounting records for conditioned and retained waste – Rating: Green
- Overall Inspection Rating – Rating: Green
Key findings, inspector’s opinions and reasons for judgement made
In accordance with the Office for Nuclear Regulation (ONR) Integrated Inspection Strategy (IIS) 2023/24 for Dounreay Division of Magnox Ltd.; hereafter referred to as Dounreay. ONR Safeguards conducts Safeguards compliance inspections at the Dounreay site. One such intervention was performed to inspect Dounreay’s compliance with the requirements of the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19) in relation to nuclear material accountancy of the Dounreay facilities; DN016, DN029, D3110, D8570, and D9867. For this intervention, the Material Balance Areas (MBAs) known as QDR4 and QDR6 were selected. Two pieces of regulatory intelligence informed the proposed scope of this inspection. The first, Dounreay have recently reported an issue in discrepancies between plant and the ATOM system resulting in misreporting information to ONR (INF-3218). The second, ONR is aware that Dounreay’s list for obligated material is based on historic information and may require updating.
This inspection sought to collect evidence of arrangements and their implementation to make judgements of compliance against NSR19 Regulations 6, 7, 9, 12, 15, 19, 29.
I conducted an accountancy inspection, focussing on the MBAs QDR4, QDR6 at the Dounreay nuclear licensed site. Dounreay informed me that the buildings selected as part of my sample did not fall within the QDR7 MBA, so I decided focus on the remaining two MBAs. The inspection comprised of discussions with staff, demonstration of accountancy systems, and reviews of associated procedures, operating and accounting record.
The inspection targeted two components. First, the operator’s procedures for accounting and managing retained waste. Second, the operator’s procedures for accounting and managing obligated material. This involved a demonstration of the associated accountancy procedures, the nuclear material accountancy (ATOM) system, and review of traceability from operator records to the associated accountancy reports.
This intervention was performed in line with ONR’s guidance (as described in the relevant technical inspection and assessment guides, which can be found on ONR’s website (onr.org.uk).
Based on the sample I inspected, I judge that Dounreay has adequately implemented the following elements of a systems for the accountancy and control of qualifying nuclear material;
A system to track and manage retained waste and obligated material within DN016, DN029, D3110, D8570, and D9867.
A system to generate accurate accountancy records and reports.
I identified a single minor shortfall against the ONR Material Accountancy, Control and Safeguards Assessment Principles (ONMACS) Material Accountancy and Control Expectation (MACE) 10.2 Quality Assurance and Control Measures in relation to the operator’s quality assurance of the Physical Inventory Take (PIT). A regulatory issue has been raised to address this.
I provided six pieces of regulatory advice relating to documentation changes, ensuring staff engagement in upcoming projects and justifying sample sizes against international standards. I raised a single positive observation as part of the inspection.
Based my discussions with relevant staff, review of associated procedures, operating records, and accountancy reports, and demonstration of the ATOM accountancy system; I judge that Dounreay are adequately tracking and managing retained waste and obligated material within QDR4, QDR6 required by NSR19 Regulations 6, 7, 9, 12, 15, 19, 29 and FSEs 7 Nuclear Material Tracking and 8 Data Processing.
Conclusion
Based on the sample inspected, I judge that Dounreay are adequately tracking and managing retained waste and obligated material and accurately reporting it as part of nuclear material accountancy reports to ONR within DN016, DN029, D3110, D8570, and D9867. The implementation of these arrangements is supporting the accountancy and control of QNM in-line with regulatory expectations FSE7 and FSE8 and are compliant with regulations 6, 7, 9, 12, 15, 19 and 29 of NSR19.
I identified a single shortfall against The ONR Material Accountancy, Control and Safeguards Assessment Principles (ONMACS) Material Accountancy and Control Expectation (MACE) 10.2 Quality Assurance and Control Measures in relation to the operator’s quality assurance of the Physical Inventory Take (PIT) as follows;
Regulatory Issue 11839 – Procedure WD-OI-022 PIT utilised by the Waste & Environmental Delivery Team (WED Team) does not include adequate quality assurance and oversight of the PIT. A regulatory issue has been raised to address this, RI-11839.
Upon consideration of the ONR guidance on inspection ratings, I judge that a rating of green (no formal action) is appropriate.