Executive summary
Date(s) of inspection
- June 2026
Aim of inspection
ONR has selected to undertake this inspection to follow up on the Enforcement Letter, dated 16 July 2024, Unique Number: ONR-EL-24-007.
The COMAH competent authority (ONR and SEPA) intends to focus on the compliance against the duties imposed under the Control of Major Accident Hazards Regulations 2015 (COMAH), in particular regulations 5 and 7.
The aims of the inspection are:
- to verify that all relevant major accident hazards have been identified and evaluated
- to verify the effectiveness of the safety management system
- to enable SEPA to familiarise themselves with the site and chemical storage arrangement
Subject(s) of inspection
- COMAH - Control of Major Accident Hazards Regulations 2015 - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
NRS Dounreay (NRS-D) was inspected against the requirements of the Control of Major Accident Hazards Regulations 2015 (COMAH), with a focus on environmental arrangements and Major Accidents to the Environment (MATTE). This was a joint ONR and SEPA inspection in our capacity as the joint COMAH Competent Authority. Overall, the inspection was rated Green (no significant shortfalls).
The site demonstrated good progress in developing environmental risk assessments for COMAH-relevant substances, including nitric acid, kerosene, diesel and medium fuel oil (MFO). However, the overall COMAH environmental risk profile remains incomplete and further work is required to assess cumulative risks and demonstrate full compliance with COMAH Regulation 5.
A administrative shortfall was identified in the site's Major Accident Prevention Policy (MAPP). This was identified as part of the planning for the inspection and not within the inspection scope. It will be a simple shortfall to address as a compliant MAPP was provided to ONR in December 2024. This matter will be tracked via the existing COMAH regulatory issue (RI-12139).
A number of areas for further discussion were identified; these are not significant and will be followed up in ongoing ONR and SEPA COMAH engagement with NRS-D.
Overall, appropriate progress has been made, but further work is required to demonstrate full environmental COMAH compliance.
Conclusion
During the inspection NRS-D was able to demonstrate that it had completed environmental risk assessments for all COMAH relevant substances on site. The further evaluation of this work to consider cumulative affects had not been completed but was acknowledged by NRS-D as something that needing completing and will be undertaken once the EA/SEPA ALARP guidance is available.
COMAH
Based on the evidence provided by site and the summary I have provided above, I rate the inspection Green, no significant shortfalls. There were a number of areas of discussion/clarification identified that will be progressed as part of ongoing ONR & SEPA COMAH routine engagement.