Executive summary
Date(s) of inspection:
Aim of inspection
The principal aim is to gain evidence that Dounreay is implementing adequate arrangements for the safe management of alkali metal on the site, including storage (LC4), minimising its accumulation SFAIRP (LC32), and ensuring, SFAIRP, it cannot leak or escape from control or containment (LC34).
In addition, the storage arrangements align with COSHH and specifically meet the guidance within HSG71 (Chemical warehousing).
Subject(s) of inspection
- COSHH - Rating: Amber
- LC4 - Restrictions on nuclear matter on the site - Rating: Amber
- LC32 - Accumulation of radioactive waste - Rating: Amber
- LC34 - Leakage and escape of radioactive material and radioactive waste - Rating: Amber
Key findings, inspector's opinions and reasons for judgement made
ONR conducted a themed inspection into the licensee's arrangements for alkali metal storage across the Dounreay site. The inspection covered elements of nuclear site Licence Conditions (LC) 4, LC32, LC34 and Control of Substances Hazardous to Health (COSHH) (and associated guidance - HSG71).
I judged that the licensee had suitably identified the alkali metal inventories and its storage locations and subsequent inventory management. However, it was acknowledged that improvements to the inventory process could be made.
It is my opinion that the licensee has not captured the importance of maintaining the appropriate storage environment for alkali metal when judged against standards. Consequently, the inspection and maintenance regime has not been adequately implemented for the risk.
It is my opinion, that the risk of storing alkali metal across the Dounreay site does not meet recommended good practice. Furthermore, it is my opinion that the alkali metal storage conditions in the Prototype Fast Reactor (PFR) turbine hall, steam generator hall and Generator Transformer House (GTH) are not adequate, as the licensee has failed to safely protect the drums against uncontrolled degradation via air and moisture ingress. It is also my opinion that the licensee is not recognising when there is degradation in these areas and then commencing appropriate remedial actions.
Overall, I judge that in many areas that there is a significant shortfall against the Relevant Good Practice (RGP) when compared against the appropriate benchmarks and the licensee cannot demonstrate that the risk of alkali metal storage is adequately controlled. On this basis, I have awarded an overall rating of Amber (Seek Improvements) to this inspection.
The identified concerns have been run through ONR’s enforcement management model and it has been determined to send an enforcement letter to Dounreay management seeking corrective action. Due to previous regulatory action in this area by HSE and SEPA it was viewed appropriate that a regulatory holding to account meeting between the licensees and ONR senior management also takes place.
Conclusion
This is a themed inspection on alkali metal storage that covers elements of LC4, LC32, LC34 and COSHH. I consider that the licensee has an adequate understanding of the alkali metal inventory and provides appropriate training for operators and supervisors. I also consider that the alkali metal storage guidance (COP-2011) identifies the hazards and the appropriate storage conditions. However, I do not consider that the licensee has adequately implemented its own guidance within the appropriate risk assessments.
It is my opinion that the licensee has not captured the importance of maintaining the appropriate storage environment for alkali metal when judged against standards. Consequently, the inspection and maintenance regime has not been adequately implemented for the risk.
It is my opinion, that the risk of storing alkali metal across the Dounreay site does not meet recommended good practice (COP2011 and HSG71). Furthermore, it is my opinion that the alkali metal storage conditions in the PFR turbine hall and the PFR generator house are not adequate, as the licensee has failed to safely protect the drums against uncontrolled degradation via air and moisture ingress. It is also my opinion that the licensee is not recognising when there is degradation in these areas and then commencing appropriate remedial actions.
Overall, I judge that in many areas that there is a significant shortfall against the RGP when compared against the appropriate benchmarks and the licensee cannot demonstrate that the risk of alkali metal storage is adequately controlled. On this basis, I have awarded a rating of Amber (Seek improvements).
The identified concerns have been run through ONR’s enforcement management model and it has been determined to send an enforcement letter to Dounreay management seeking corrective action. Due to previous regulatory action in this area by HSE and SEPA it was viewed appropriate that a regulatory holding to account meeting between the licensees and ONR senior management also takes place.