- Site: Dounreay
- IR number: 21-041 (SAF)
- Date: March 2022
- LC numbers: N/A
Executive summary
Purpose of Intervention
In accordance with the Office for Nuclear Regulation (ONR) Safeguards’ integrated intervention strategy 2021/22 for Dounreay Site Restoration Ltd (DSRL), ONR Safeguards undertakes a number of safeguards compliance inspections at the DSRL site. An inspection was undertaken to assess DSRL’s compliance with the requirements of the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19) in relation to evaluating the implementation of arrangements for performing a Physical Inventory Take (PIT). The inspection sampled the PIT arrangements in the D1215 & D1218 Analytical Labs (Material Balance Area (MBA) QDR5) and the D9867 High Alpha Low Beta Gamma Solid Waste Store.
A Basic Technical Characteristics (BTC) compliance inspection was also carried out at the High Alpha Low Beta Gamma Solid Waste Store (QDR6). This inspection was originally planned to be undertaken in November 2021, however it was delayed due to adverse weather conditions restricting safe access to the facility.
Interventions Carried Out by ONR
The purpose of the QDR5-QDR6 PITe Inspection was to gain regulatory confidence that DSRL is compliant with the requirement to undertake a PIT as outlined Regulation 15 of NSR19, through the implementation of appropriate and proportionate underpinning arrangements (regulation 6 and 9). I also sought evidence to provide regulatory confidence that those arrangements are being implemented to generate operating records, accounting records, and waste stocklists that align with regulations 10, 11, and 29 of NSR19.
The purpose of the QDR6 BTC Inspection was for ONR to determine that the sampled components of DSRL’s system for accountancy and control of qualifying nuclear material (QNM) are reflected in a correct and complete manner within the D9867 High Alpha Low Beta Solid Waste Store BTC submission (SA/BTC/19, Issue 4) as required by Regulation 3 (1, 3) (Declaration of basic technical characteristics) of the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19).
The inspection comprised of discussions with DSRL staff, sampling and review of DSRL operating, accounting records and other source documentation, and plant walkdowns to check implementation of arrangements. It was carried out in line with ONR's guidance which can be found on our website.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
QDR5-QDR6 PITe Inspection
Based on the sampled evidence I judge DSRL is implementing appropriate and proportionate arrangements for the undertaking of a PIT at D1215 and D1218. I am also satisfied that DSRL is implementing appropriate and proportionate arrangements for undertaking a PIT at D9867. I found minor compliance shortfalls associated with discrepancies within the implemented arrangements at D9867 and those claimed within the Accountancy and Control Plan (ACP) and the arrangements for uniquely identifying items at D9867 do not meet ONR’s expectations. I have raised two Level 4 regulatory issues to track progress.
Based on the sampled evidence, I judge that DSRL did not provide evidence of an established framework to ensure key personnel named in the site-wide ACP are suitably qualified and experienced (SQEP) to fulfil their nuclear material accountancy and control responsibilities. I consider this to represent a significant shortfall against regulation 6(3) of NSR19 and ONR’s regulatory expectations for competence management. I will raise a Level 3 Regulatory Issue to seek improvement and monitor progress against this compliance shortfall.
QDR6 BTC Inspection
I judged that, on the evidence sampled, the duty-holder’s BTC submission for the High Alpha Low Beta Solid Waste Store was correct, complete, and reflected the current facility configuration and operations.
I identified three minor shortfalls associated with the correctness and completeness of BTC submission SA/BTC/19 (issue 4) and the implementation of DSRL arrangements for BTC review. I will raise a regulatory issue to monitor progress against both shortfalls. These were explained to and accepted by the operator. I gave one piece of regulatory advice related to the legibility of container identities within the facility. The operator accepted this feedback at the conclusion of the inspection.
Conclusion of Intervention
QDR5-QDR6 PITe Inspection
I am satisfied that DSRL is implementing appropriate and proportionate arrangements for the undertaking of a PIT at QDR5 and QDR6, and are complying with Regulations 10, 11, 15, and 29. The failures to implement arrangements claimed in their ACP, and the shortfalls in arrangements to identify items, are minor shortfalls against regulations 9(1) and 6(3) respectively. However, the absence of arrangements to ensure key personnel named in the Site-wide ACP are suitably qualified and experienced (SQEP) is a significant shortfall against NSR19 and ONR expectations that requires improvement. I therefore rate this aspect of the inspection as amber, and I am seeking improvement.
QDR6 BTC Inspection
Based on the evidence sampled during this compliance inspection, I am satisfied that operators BTC submission for the High Alpha Low Beta Solid Waste Store was broadly correct, complete, and reflected the current facility configuration and operations. Therefore, it is my opinion that, against compliance with NSR19 regulation 3 (1, 3) (declaration of a basic technical characteristics), an inspection rating of green (no formal action) is merited.