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Compliance inspections against LC23, LC24 and LC26

  • Site: Dounreay
  • IR number: 19-050
  • Date: June 2019
  • LC numbers: 23, 24, 26

Executive summary

Purpose of Intervention

The purpose of this intervention was to undertake a Licence Condition (LC) compliance inspection at Dounreay Site Restoration Limited (DSRL) in accordance with the 2018/19 Integrated Intervention Strategy (IIS) for Dounreay to confirm that the licensee is controlling its hazards and complying with its statutory obligations.

Interventions Carried Out by ONR

This intervention included an inspection of the site’s arrangements made under the following LCs:

  • LC23 (Operating Rules)
  • LC24 (Operating Instructions)
  • LC26 (Control and Supervision of Operations)

It examined a sample of the licensee’s arrangements and their implementation in support of operations / decommissioning activities within the following areas on site:

  • D1208 [Waste Programme]
  • D2001 [Fuels Programme]
  • DFR [Reactors Programme]
  • D2850/D1203 [Fuels Programme]

This intervention provided the opportunity to review the arrangements in support of the Direct Ship work stream. It also provided the opportunity receive an update of DSRL progress to address regulatory issue 7234 that was raised during an LC35 intervention in May 2019.

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A

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

DSRL’s arrangements, and their implementation, for operating rules and operating instructions were examined in a number of facilities across the site. In each of these facilities evidence of a clear line of sight from the safety case to operating instructions of key operating limits and conditions was observed. All documentation sampled was appropriate for its application and up-to date. During the inspection a minor shortfall with respect to the change control arrangements for a fuels inventory data sheet was identified and a level 4 regulatory issue has been raised to track the corrective action. Overall ONR is satisfied that DSRL has adequate arrangements for the identification and promulgation of the limits and conditions resulting from the safety assessments undertaken in support of nuclear activities across site. 

This inspection is part of a continuing theme of activities focused on assessing DSRL’s arrangements for the control and supervision of high hazard operations. It was carried out concurrently with the inspection of arrangements for operating rules and operation instructions and assessed the application of arrangements for control and supervision of activities the facilities visited. ONR observed that supervisors have a clear understanding of the activities, risks and hazards within their facilities, they make good use of routine handovers and briefs to ensure key information is provided to those that need it. Additionally appropriate use is being made of permit to work systems and training of supervisory staff is both adequate and up-to date. Therefore, from the areas sampled during this inspection, ONR is satisfied that DSRL has adequate arrangements in place for the control and supervision of operations.

Conclusion of Intervention

Overall, ONR considers that the arrangements and their associated implementation for LC23, LC24 and LC26 for the areas inspected met with the required standards. One regulatory issue has been raised to address a shortfall regarding the change control arrangements for a fuels inventory data sheet. No matters impacting on nuclear safety that required immediate regulatory action were identified during the inspection.