- Site: Dounreay
- IR number: 21-015 (SAF)
- Date: July 2021
- LC numbers: N/A
Executive summary
Purpose of Intervention
This inspection was one of a programme of planned inspections at Dounreay Site Restoration Ltd. (DSRL) during 2022/2023, developed in accordance with the Safeguards Sub-Division Strategy. This inspection was an accountancy focussed inspection of operator arrangements against The Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19).
Interventions carried out by ONR
ONR nuclear safeguards inspectors and I conducted an accountancy compliance inspection of Dounreay Site Restoration Ltd. (DSRL), focussing on the facilities involved in the accountancy and control of qualifying nuclear material (QNM) in the form of retained waste in Material Balance Area (MBA) QDR6 (including D9867, D1208, D2700, and D8570). The inspection also examined the accountancy of low-level discharges of QNM to the Environment. This inspection sought to collect evidence of arrangements and their implementation to make judgements of compliance against NSR19 Regulations 6(3), 9(1) and 29(1). The inspection comprised of discussions with staff, reviews of operating and accounting records, and a plant walkdowns for sampled plants within the QDR6 MBA.
The inspection targeted the operating and accounting records underpinning reported inventories of QNM in the form of retained waste, transactions of QNM to/from retained waste, and transfers of QNM to the environment. I sought assurance that transactions were underpinned by appropriate source documents generated by the adequate implementation of relevant arrangements and procedures for nuclear material accountancy and control (NMAC). I also sought assurance that those arrangements and procedures align with arguments made in relevant Accountancy and Control Plans (ACPs)
This intervention was performed in line with ONR's guidance (as described in the relevant technical inspection guides, which can be found on our website.
Key findings, inspector's opinions and reasons for judgements made
No significant shortfalls in compliance against NSR19 were identified during this intervention.
The maintenance of retained waste stock lists
On the basis of the stock list and source documentation sampled, I am satisfied that DSRL are adequately implementing arrangements to maintain and update a retained waste stock list and adequate source documentation to determine changes in the quantities and composition of retained waste. I am satisfied that DSRL are complying with the requirements of NSR19 regulations 29(1)(a) and 29(1)(b) in this regard. I am satisfied that their records of retained waste include all changes to the stock of retained waste, so that the book inventory of retained waste can be established when requested, in line with NSR19 regulation 29(1)(e). In explaining those changes to the stock of retained waste, DSRL identified a minor mistake in the reported quantities of HEU transferred to retained waste. I consider this a minor shortfall against regulation 12(2) and advised DSRL that they must correct this mistake at the next opportunity. On the basis of the source documentation presented to me throughout the course of the inspection for the sampled items, I am satisfied that the retained waste stock list correctly records the sampled items of retained waste.
The accountancy and control of retained waste
Based on the arrangements and source documentation sampled, I judge that DSRL are implementing adequate arrangements to track retained waste in D1208, D2700, and D9867 in line with MACE 7.1. I am also satisfied that these arrangements align with arguments made in accountancy and control plans for those facilities, in compliance with regulation 9.1. The source documentation substantiated the accountancy records for the sampled items
The reporting of terminations to the environment
I am satisfied that DSRL are implementing adequate arrangements to account for the termination of nuclear material within their retained waste account, and that termination can be substantiated through adequate source documentation - in compliance with regulation 29(1)(b). I am also satisfied that DSRL are implementing adequate arrangements to report those terminations in compliance with Part 2 of Schedule 1 of NSR19.
Conclusion
Based on the sample inspected during the intervention I judge that DSRL is compliant with the requirements of regulations 6(1), 9(1) and 29(1) in the areas sampled, noting a minor shortfall against regulation 12 (2) relating to the accuracy of historic accountancy reports. I provided regulatory advice regarding the correction of historic reporting accuracies and this shortfall shall be remedied through the next Inventory Change Report (ICR).
I gave two other pieces of regulatory advice relating to transparency of changes to the retained waste account and the application of particular obligation codes to terminations to the environment. I observed good practice in the production of an ad-hoc retained waste balance report submitted by DSRL as part of this inspection.
Upon consideration of the ONR guidance on inspection ratings, I judge that a rating of GREEN (no formal action) is appropriate.