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Dounreay - LC compliance inspection (LC28, LC32, LC34)

  • Site: Dounreay
  • IR number: 19-144
  • Date: December 2019
  • LC numbers: 28, 32, 34

Executive summary

Purpose of Intervention

The purpose of this inspection was to confirm Dounreay Site Restoration Limited (DSRL) compliance with specific Licence Conditions [LC] and to undertake a system based inspection  in accordance with the 2019/20 Integrated Intervention Strategy (IIS) for the site, 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:

  • LC32 [Accumulation of radioactive waste]
  • LC34 [Leakage and escape of radioactive waste and radioactive material]

This inspection included a follow up inspection against LC 28 [Examination, inspection, maintenance and testing].

The intervention also provided the opportunity to attend the Dounreay & Vulcan Off-Site Emergency Planning Group held at Inverness on 5 Dec 19. 

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable.

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

The LC28 inspection focused on an assessment of the evidence provided to support the formal close out of a regulatory issue. This issue was raised to address concerns identified against the adequacy of maintenance records during the LC25 compliance inspection conducted 13 November 2017.

DSRL provided clear evidence of a significant improvement in both the quality of the maintenance records sampled and in the safety culture within the site maintenance teams. The improvement activities implemented by the Site Maintenance Authority including a schedule of random sampling of records has also driven significant improvements in the quality and suitability of the records necessary to support the site’s maintenance requirements.

Overall we were satisfied that the corporate arrangements and their implementation within the areas inspected met the legal requirements of LC28.

The LC32/LC34 inspection focused on an assessment of the implementation of DSRL corporate arrangements for storage of wastes and the leak and escape of radioactive material [including wastes]. This involved an inspection of how written arrangements had been implemented and the condition of assets used for containment, monitoring and detection.

This inspection also provided the opportunity to review the improvements implemented following the previous LC32 inspection of July 2019.   DSRL provided clear evidence of a number of improvements to the management of radioactive waste, in particular, how waste packages are labelled and the storage arrangements within the PFR. 

DSRL also gave an account of the wastes and radioactive material stored at the site and how leaks and escape would be detected.  Local management arrangements were inspected and records were sampled. 

We also inspected the arrangements for storage and inspection of ILW packages: ONR has requested that DSRL provide clarification on how these arrangements will be implemented within the new DCP store extension.

Overall we are satisfied that the corporate arrangements and their implementation within the areas inspected met the legal requirements of LC32 and LC34.

Conclusion of Intervention

Overall, we consider that DSRL’s arrangements and their implementation in those areas inspected meet the legislative requirement of LC28, LC32 and LC34.  We did not identify any matter impacting on nuclear safety that required any further immediate regulatory action.