- Site: Dounreay
- IR number: 21-051
- Date: July 2021
- LC numbers: 11, 26
Executive summary
Purpose of Intervention
The purpose of this inspection was to undertake compliance inspections at Dounreay Site Restoration Limited (DSRL) in accordance with the 2021/22 Integrated Intervention Strategy (IIS) for Dounreay to confirm that the licensee is controlling its hazards and complying with its statutory obligations and, to attend the Annual Review of Safety, Security and Safeguards (AROSSS).
Interventions Carried Out by ONR
The inspections were conducted by a team comprising ONR Nuclear Safety, Conventional Health & Safety, and Transport Safety Inspectors. The inspections examined the suitability of arrangements and their implementation against the following legislative requirements:
- LC11 – Emergency arrangements [Transport].
- LC26 – Control and supervision of operations.
- Construction Design and Management (CDM) Regulations 2015.
- Lifting Operations and Lifting Equipment Regulations (LOLER) 1998.
- Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations (CDG) 2009.
The intervention also provided the opportunity to conduct inspections against the following:
- Review of progress against Regulatory Issues and Agreed Regulatory Actions.
- Review of DSRL’s Internal Regulation capability.
- Meeting with the Site Safety Representatives.
- The nominated Site Inspector also attended a ‘virtual’ meeting of the Dounreay Sites Stakeholder Group [Site Resilience Group].
Explanation of Judgement if Safety System Not Judged to be Adequate
Not applicable.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
The Transport Emergency Table-Top Exercise provided an opportunity to assess Dounreay’s arrangements against the requirements of LC11 and CDG 2009. The exercise involved representation from each of the external stakeholder groups and highlighted a number of valuable learning opportunities. Overall, we are satisfied that DSRL has adequate arrangements to respond to an off-site transport emergency.
The CDM inspection focused on the implementation of the regulations in support of the construction activities within the DCP Stores Extension Enclave. This inspection also provided an opportunity to assess the control and supervision of construction activities. We are satisfied that DSRL has adequate arrangements to meet the requirements of CDM and that these have been adequately implemented in support of the DCP Stores Extension Project. We are also satisfied that DSRL demonstrated an adequate level of control and supervision of activities within the construction enclave.
The Inspection of LOLER focused on the corporate arrangements and the identification and learning from operational experience. We are satisfied that the arrangements have undergone a significant review and update and meet the regulatory requirements of LOLER.
The CDG inspection focused on the provision and implementation of adequate management systems for the conduct of nuclear material transport. This involved a plant visit to DFR to inspect the arrangements supporting the transport of DFR blanket Material from Dounreay to Sellafield. Overall, we are satisfied that DSRL has adequate arrangements in place to support the transport of nuclear material.
At the AROSSS, DSRL provided a succinct summary of their performance over the past year and provided a forum to discuss their future programme, in particular, those activities they considered posed the more significant challenge and regulatory risk. We are satisfied that the performance reported by DSRL aligned with that of the ONR Site Inspectors and welcomed the opportunity to discuss the principles by which ONR implements an enabling regulation approach to permissioning.
We remain satisfied that DSRL continues to make adequate progress to address the action plans associated with Formal Regulatory Issues and ‘Agreed Regulatory Actions’. In addition, we remain satisfied with the increased profile and role the site’s internal assurance team plays in the oversight and governance of high hazard projects.
Conclusion of Intervention
Overall, we consider that DSRL has and has implemented adequate arrangements to meet the requirements of the legislation covered by this intervention in those areas inspected. In addition, we consider that DSRL continues to make satisfactory progress to address regulatory issues raised during previous inspections. We did not identify any matter impacting on nuclear safety that required any further immediate regulatory action.