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Dounreay - Level 1 Demonstration Exercise, IRR17 and LC compliance inspections

  • Site: Dounreay
  • IR number: 21-083
  • Date: September 2021
  • LC numbers: 7, 11

Executive summary

Purpose of Intervention

This was one of a series of planned inspections of arrangements made under Licence Conditions (LC) by 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.

Interventions Carried Out by ONR

This inspection included an assessment of the Site’s annual demonstration emergency exercise Delta 56 conducted against the requirements of LC11(5) (Emergency arrangements).

This intervention also included an inspection of the site’s arrangements made under Ionising Radiation Regulations 2017 and LC7 (Incidents on the site).

The inspections were undertaken based on examining a sample of the licensee’s arrangements and their implementation on site. The IRR17 inspection covered the implementation of those arrangements within:

  • DFR.
  • D1204 Decommissioning Project.

This inspection also provided the opportunity to undertake an inspection of DSRL’s arrangements for RPE as part of an ONR cross-industry themed inspection.

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A

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

The LC7 compliance inspection provided the opportunity to review DSRL’s progress to improve their incident and event reporting, investigation and, learning from operational experience arrangements.  DSRL has now implemented a new reporting system which offers a number of improvements over the previous system.  ONR identified opportunities for improvements in DSRL’s governance of these arrangements but remains satisfied that DSRL’s arrangements for the reporting and investigation of incidents on the site to be adequate against the requirements of the Licence Condition.

The LC11 compliance inspection covered a formal review of those aspects of the on-site Emergency Preparedness and Response (EP&R) Capability Map covering ‘Assessment’ and ‘Prevention’. Overall ONR is satisfied that the evidence examined provided an adequate demonstration of the regulatory expectations specified within ONR’s guidance.

The LC11 compliance inspection also included the assessment of the site’s annual Level 1 safety demonstration emergency exercise [Delta 56]. Overall, we consider that the exercise provided an adequate demonstration of the site’s emergency arrangements and their capability to deal with an emergency on site.  In accordance with ONR’s arrangements, a letter will be forwarded to site in due course with our formal assessment and feedback on those areas where the site performed well and those areas identified for improvement

Overall we are satisfied that DSRL’s arrangements for LC11 demonstrate compliance against the legal requirement of the Licence Condition and the regulatory expectations provided within ONR’s guidance.

The inspection against the IRRs included a review of the sites responses to a questionnaire for a multisite intervention on the use of respiratory protective equipment (RPE), public exposures, the sites general arrangements for IRR17 compliance and the implementation of those arrangements in DFR and D1204. ONR noted an example of good practice and some opportunities for improvement. ONR agreed to provide further questions for clarification of the DSRL questionnaire responses as part of the multisite RPE intervention at a date to be confirmed. Overall ONR is satisfied that DSRL provided an adequate demonstration of compliance with IRR17 requirements.   

Conclusion of Intervention

Overall, we consider that the arrangements and their associated implementation for LC7, LC11 and IRR17 in the areas inspected met with the required standards.  Additionally, we consider that the annual site Level 1 Demonstration emergency exercise provided an adequate demonstration of the site’s emergency arrangements against the requirements of LC11. We did not identify any matter impacting on nuclear, radiological, or conventional safety that required any further immediate regulatory action.