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LC compliance inspection and System Based Inspection (Resilience arrangements)

  • Site: Dounreay
  • IR number: 19-131
  • Date: November 2019
  • LC numbers: 10, 12

Executive summary

Purpose of Intervention

The purpose of this inspection was to undertake Licence Condition [LC] compliance inspections and a system based inspection at Dounreay Site Restoration Limited (DSRL) in accordance with the 2019/20 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

The compliance inspections assessed the arrangements in place and their implementation against the requirements of the following LCs:

  • LC10 [Training]
  • LC12 [Duly authorised and other suitably qualified and experienced persons]

The systems based inspection (SBI) was focused on DSRL’s Resilience arrangements and assessed those arrangements and their implementation against the requirements of the following LCs:

  • LC10 - Training;
  • LC23 - Operating rules;
  • LC24 - Operating instructions;
  • LC27 - Safety mechanisms, devices and circuits;
  • LC28 - Examination, inspection, maintenance and testing.

This inspection also provided the opportunity to follow up on ONR’s formal review of those internal regulation activities not covered during the intervention conducted in October.  In addition I conducted a number of plant visits as part of ONR’s rolling schedule of inspection activities to assess DSRL’s performance against the regulatory expectations for LC26 [Control and supervision of operations]. 

Explanation of Judgement if Safety System Not Judged to be Adequate

I consider that the arrangements examined to support the DSRL Resilience requirement and their implementation in the areas inspected to be adequate against the requirements of the above licence conditions.

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

DSRL provided clear evidence of a systematic approach to the identification, provision and assessment of their training requirement and the direct link this has to the provision of duly authorised and suitably qualified and experienced personnel.  There is also good evidence that, where applicable, behaviours and people management skills are also defined and assessed.

I found clear evidence that these arrangements are applied consistently across all operational areas. Those with supervisory duties were able to demonstrate adequate control and oversight of their staff’s training and competencies using the records provided via the corporate U4BW system.

Overall I am satisfied that the corporate arrangements and their implementation within the areas inspected met the legal requirements of LC10 and LC12 and the regulatory expectations enshrined within ONR’s guidance.

The plant visit to DFR provided the opportunity to observe fuel element operations as part of the overarching reactor decommissioning programme.  I am satisfied that the level of control and supervision witnessed meets the regulatory expectations of LC26.

Conclusion of Intervention

Overall, I consider that the assumptions and safety functional requirements underpinning the provision of a site resilience capability have been implemented adequately against the requirements of those licence conditions covered by the SBI.  Furthermore I am satisfied that DSRL has adequate arrangements in place to meet the legal requirement and the regulatory expectations against LC10 and LC12.  I did not identify any matter impacting on nuclear safety that required any further immediate regulatory action.