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Dounreay - Readiness Review of the Restart of Operations

  • Site: Dounreay
  • IR number: 20-024
  • Date: August 2020
  • LC numbers: 8, 9, 10, 12, 24, 26, 28

Executive summary

Purpose of Intervention

The purpose of this inspection at Dounreay Site Restoration Limited (DSRL) was mainly to assess the site’s arrangements for the restart of operational activities.  These inspections are being conducted in accordance with the 2020/21 Integrated Intervention Strategy (IIS) to confirm that the licensee is controlling its hazards and complying with its statutory obligations.

Interventions Carried Out by ONR

ONR undertook inspections of the site’s arrangements and their implementation for the restart of operational activities within the following areas:

  • D1208 (High Active Liquor Storage, Treatment and Evaporation Plant);
  • Project Delivery (ADU Floc Project).

Where it has been judged appropriate to do so, ONR has assessed those activities against the requirements of the following Licence Conditions (LCs):

  • LC8 (Warning notices)
  • LC9 (Instructions to persons on the site)
  • LC10 (Training)
  • LC12 (Duly authorised and other suitably qualified and experienced personnel)
  • LC24 (Operating instructions)
  • LC26 (Control and supervision of operations)
  • LC28 (Examination, maintenance, inspection and testing)

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A

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

I assessed the arrangements in place for the safe return of staff to operational areas. I am satisfied that DSRL has implemented adequate arrangements within the operational areas, specifically work areas D1208 and the ADU Floc project, to meet the guidelines set out by UK and Scottish Government and to meet their legislative duty under the Health and Safety at Work etc Act 1974.  These arrangements have been supported by an effective communications plan comprising ‘social media, an App, videos, teleconferences and familiarisation visits to provide staff with the information necessary to support their return to site and the operational areas.  Return to work is controlled via a series of checklists to ensure personnel receive the necessary briefings and other additional training required to support their return to work. I am satisfied that DSRL has implemented a considered and pragmatic approach that balances the need to provide the necessary assurances regarding radiological contamination against the potential for cross-contamination of Covid-19.

I am also satisfied that, despite the nature of the Covid-19 threat and the changes in guidance as government policy evolves, DSRL’s management of their response to the Covid-19 requirement, specifically management of warning notices, instructions to persons on site and training, have been conducted in accordance with their extant arrangements. Based on the evidence examined, I am satisfied that DSRL remains compliant with the requirements of L8, LC9 and LC10.

I assessed the arrangements in place for the restart of operational activities within the Waste and the Project areas, specifically D1208 and the ADU Floc.

Within each of the areas I assessed the arrangements in place to secure the continued protection of personnel in the conduct of their operational tasks; I assessed the arrangements for ensuring that engineered safety systems and plant were fit for purpose and in a suitable state to support the restart of operational activities.  I assessed the arrangements by which the limits and controls for safe operations were reviewed to account for changes in restrictions or system status and, the revisions as appropriate to extant operating instructions.  I also assessed the arrangements by which operator SQEP was assured, in particular addressing the potential for skill fade during a prolonged period away from plant operations.

I also took the opportunity to observe activities that had recently recommenced focusing on the implementation of revisions due to Covid-19 and revised plant status.  I am satisfied, based on these observations, that the level of control and supervision witnessed supports the safe restart of operations following a period of prolonged plant shut down.  

Overall, within the operational areas inspected, I am satisfied that there was clear evidence of a systematic approach to the safe restart of operations. The arrangements in place demonstrated a considered review of the status of the plant, the competency and currency of the personnel and, the suitability of the operating documentation.  Additionally I am satisfied that the governance associated with the restart of operations has been robust and transparent.  On that basis I judge that DSRL remains compliant with the requirements and regulatory expectations of L12, LC24, LC26 and LC28.

Overall, ONR is satisfied that DSRL continues to demonstrate adequate control and supervision of its activities. 

Conclusion of Intervention

I consider that the arrangements and their associated implementation for the safe return of staff to site and for the restart of operations in the areas inspected met with the required standards.  I did not identify any matter impacting on nuclear safety that required any further regulatory action.