- Site: Dounreay
- IR number: 20-051
- Date: October 2020
- LC numbers: 8, 9, 10, 11, 12, 24, 26, 28, 36
Executive summary
Purpose of Intervention
The purpose of this inspection at Dounreay Site Restoration Limited (DSRL) was to assess the site’s arrangements for the safe 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:
- D1203 (Fuel Programme);
- D1204 (FCA Decommissioning).
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 site)
- LC10 (Training)
- LC11 (Emergency arrangements)
- 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)
ONR also undertook a compliance inspection against the requirements of LC36 with a specific focus on the Management of Organisational Change.
In addition, this intervention also provided the opportunity to conduct other inspections, specifically:
- Review of progress against regulatory issues as recorded on the ONR Regulatory Issues Database and other regulatory actions agreed during previous ONR inspection activities;
- Meeting with the site safety representatives;
- Review of DSRL’s internal regulation activities.
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 restart of operational activities in support the Fuels Programme and within the FCA Decommissioning Operational Area, specifically D1203 and D1204.
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 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; 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.
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 LC8, LC9, LC10, LC11, L12, LC24 LC26 and LC28.
ONR also assessed the corporate arrangements for the management of organisational change (MoC) and the implementation of those arrangements in support of the MoC submissions covering the reorganisation of the Security and Resilience Directorate and the transition of Dounreay into a wholly owned subsidiary of the NDA. Overall ONR is satisfied that the arrangements and their implementation in support of the MoC submissions examined meet the requirements of LC36 and the regulatory expectations enshrined within ONR’s guidance.
ONR also reviewed the internal regulation activities supporting the governance of major projects currently undergoing inactive commissioning. ONR remains satisfied that DSRL’s internal regulation capability provides an adequate independent challenge and oversight of those activities. I also observed the key role the DSRL Independent Assessment Team provides in the verification of the evidence supporting the restart of operations.
Conclusion of Intervention
I consider that the arrangements and their associated implementation for the safe restart of operations in the areas inspected met with the required standards. The arrangements for the management of organisational change meet the requirements and regulatory expectations of. In addition, ONR is satisfied that DSRL has an effective internal regulation capability that continues to play an effective role in support of the governance of site activities.
I did not identify any matter impacting on nuclear safety that required any further regulatory action.