Dounreay - Inspection ID: 52178

In accordance with the Office for Nuclear Regulation (ONR) Integrated Inspection Strategy (IIS) 2023/24 for Dounreay Division of Magnox Ltd.; hereafter referred to as DSRL, ONR Safeguards conducts Safeguards compliance inspections at the DSRL site. This intervention was performed to inspect DSRL’s compliance with the requirements of the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19) in relation to operation of the Physical Inventory Take (PIT). For this intervention, the Material Balance Area (MBA) known as QDR6 (D1208 (Medium Active Liquor Treatment (FLOC Plant) was selected, and the inspection planned as a Physical Inventory Take Evaluation (PITe) focused compliance inspection. 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). I conducted an accountancy and PITe compliance inspection, focussing on the MBA QDR6 at the DSRL nuclear licensed site. The inspection comprised of discussions with staff, review of measurement procedures, demonstration of accountancy systems, operation of physical inventory takes, and reviews of associated procedures, operating and accounting records. The inspection targeted two areas: The operator’s procedures for performing a PIT and producing the associated accountancy reports; including the measurements underpinning these reports and the Accountancy and Tracking of Materials (ATOM) nuclear material accountancy system. This involved a demonstration of the ATOM system and review of traceability from operator records to the associated accountancy reports. This intervention was performed in line with ONR's guidance (as described in the relevant technical inspection and assessment guides, which can be found on ONR’s website (onr.org.uk). I identified two minor shortfalls as part of the inspection as follows;

• A minor shortfall in the implementation of adequate quality assurance for the material balance report (MBR) in accordance with NSR19 Schedule 2 6(3). This resulted in an error in the submitted report requiring a minor correction. A minor regulatory issue has now been raised for DSRL to investigate the cause of this error and propose a solution to prevent it from re-occurring.
• A minor shortfall against NSR19 9(1). Non-compliance with an internal procedure  requiring the production of a form for the general areas of D1208; as described within the Accountancy and Control Plan (ACP). Although the check was conducted in accordance with the procedure. The associated form was not produced as no material was present. I raised this as regulatory advice that this form should be updated to reflect a zero value, Progress against this will be tracked at ongoing level 4 meetings.

Based on the sample I inspected, I judge DSRL has adequately implemented the following elements;

• A measurement program as described within the ACP.
• A system to track qualifying nuclear material and retained waste within D1208.
• A data-processing system as claimed within the ACP.
• A system to document and produce accountancy reports.

Based on the demonstration of ATOM, discussions with relevant staff, and review of associated procedures I judge that DSRL are implementing the arrangements described in their ACP as required by NSR19 Regulation 9 and that the implementation of these arrangements is supporting the accountancy and control of qualifying nuclear material (QNM) within these MBAs as required in NSR19 Regulation 6. I provided an additional piece of regulatory advice surrounding the reported figures within the ICR and the consolidation of these figures. No observations were raised as part of the inspection.