Executive summary
Date(s) of inspection
May 2025
Aim of inspection
This intervention is to inspect the adequacy of Dounreay’s Pressure Systems Safety Regulations (PSSR) compliance arrangements and to review the condition of the site’s steam and other pressure systems. The intervention will consider site arrangements for maintaining assets in a safe condition, the organisational arrangements for managing compliance and the competence of the organisation. This will be achieved via review of Dounreay safety processes & documentation, consideration of pre-audit material received, discussions held with site representatives and site walkdowns.
Subject(s) of inspection
- PSSR - Rating: GREEN
Key findings, inspector's opinions and reasons for judgement made
ONR decided to undertake this Pressure Systems Safety Regulations (PSSR 2000) intervention following a steam leak from the fuel cycle area steam ring main in 2023, its removal from service thereafter and other recent history of PSSR 2000 related non-compliances reported by the PSSR 2000 Competent Person, Bureau Veritas.
Prior to the intervention, the ONR inspectors obtained relevant documents and held pre-intervention engagements with NRS Dounreay. During the intervention that spanned over two days ONR inspectors held meetings with various NRS Dounreay personnel on specific matters including inter alia the learnings from the fuel cycle area steam ring main incident, undertook walkdowns of the various systems inside and outside the facilities which are relevant to PSSR 2000, reviewed documents related to new pipework designs, sampled records and evidence of maintenance, wider asset management programmes and looked at the competency arrangements for personnel responsible for the pressure systems.
ONR inspectors observed that the pressure systems inside the sampled facilities were maintained in good condition, with clear ownership. However for the site wide pressure systems there has been evidence of significant lack of maintenance and ownership. Following discussion with NRS Dounreay it transpired that there are gaps within the organisation in understanding the roles and responsibilities for maintenance and compliance of the across site systems. Whilst the lack of maintenance could be deemed as a shortfall against PSSR 2000 Regulation 12 (Maintenance), however, NRS Dounreay had remediation plans in place to address the gaps, ONR inspectors judged regulatory action was not required in this occurrence. A single Level 4 regulatory issue has been raised to monitor NRS’s progress in rectifying defects on a specific degraded length of pipework.
Considering the lack of clarity about the roles and responsibilities for maintenance, ONR inspectors have advised NRS Dounreay too improve communication across the workstreams such that there is sufficient information available in the tools like “Mainsaver” used by the personnels to undertake the activities and demonstrate compliance.
Conclusion
Based on the discussions held, walkdowns undertaken and reviewed evidence, we judged that whilst there are some shortfalls against the expectations of PSSR 2000; however NRS Dounreay have demonstrated that they have remedial action plans with defined timescales. We also recognised that NRS Dounreay has good arrangements in place with suitably qualified personnel (e.g. Senior Pressure Systems Advisor) to manage and undertake compliance activities as required by PSSR 2000. Further, we noted that following the revised plan for decommissioning, NRS Dounreay has developed targeted plans for asset care management and maintenance, sponsored and led by its senior management representatives. We judged this to be important because following discussion with NRS Dounreay we gained confidence that there will be adequate focus assigned by the senior management to embark on tangibly achievable remedial plans to address the identified shortfalls and demonstrate a culture of compliance against PSSR 2000 requirements.
Overall, we judged that whilst we identified certain gaps with maintenance, in general the pressure systems are in a reasonable state of maintenance. A single Level 4 regulatory issue has been raised to monitor NRS’s progress in rectifying defects on a specific degraded length of pipework.
Notwithstanding the Level 4 regulatory issue raised, ONR inspectors are satisfied that NRS Dounreay has generally demonstrated good understanding of the PSSR 2000 requirements and that the inspection merits a GREEN rating.