Executive summary
Date(s) of inspection:
Aim of inspection
ONR nuclear safeguards inspectors conducted an Accountancy and Control Plan Inspection of Dounreay – Dounreay Division of Magnox Ltd. on 27 June 2023. The purpose of this inspection was to seek evidence in support of Dounreay’s compliance with The Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19) in relation to implementation of the Accountancy and Control Plan (ACP). For this intervention, the Material Balance Area (MBA) known as QDR4 - Uranium Conversion Plant and Fissile Material Store was selected.
ONR formed regulatory judgements and provided a rating, in line with ONR’s inspection rating guidance, of Dounreay’s compliance against Regulations 6, 7, 9 and 17 in NSR19:
To form effective regulatory judgements on Dounreay’s compliance with the NSR19 regulations listed above, ONR considered ONMACS expectations, with a particular focus on· Fundamental SSAC Expectations (FSEs) as outlined in the ONR Guidance for Nuclear Material Accountancy, Control and Safeguards (ONMACS), Issue 5; FSE 3, 4, 6, 7 and 10.
Subject(s) of inspection
- FSE 10 Quality Assurance and Control for NMACS - Rating: GREEN
- FSE 3 Competence Management - Rating: GREEN
- FSE 4 Reporting, Anomalies, and Investigations - Rating: GREEN
- FSE 5 Reliability, Resilience and Sustainability - Rating: GREEN
- FSE 7 Nuclear Material Tracking - Rating: GREEN
- NSR19 Reg06 - Accountancy and control of qualifying nuclear material - Rating: GREEN
- NSR19 Reg07 - Accountancy and control plan - Rating: GREEN
- NSR19 Reg09 - Operation of an accountancy and control plan - Rating: GREEN
- NSR19 Reg17 - Unusual occurrences - Rating: GREEN
Key findings, inspector's opinions and reasons for judgement made
I conducted an accountancy and ACP inspection, focussing on the MBA QDR4 at the Dounreay nuclear licensed site. The inspection comprised of discussions with staff, review of measurement procedures, demonstration of accountancy systems, review of competence, review of incident reporting, and reviews of associated procedures, operating and accounting records.
The inspection targeted two components. First, the operator’s ACP, and the effective implementation of the associated procedures. Second the operator’s procedures for incident reporting. This involved a demonstration of the associated measurements, accountancy, and training supporting this procedure. A demonstration of the nuclear material accountancy (ATOM) system and review of traceability from operator records to the associated accountancy reports was provided.
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 no shortfalls as part of the inspection and based on the sample I inspected, I judge Dounreay has adequately implemented the following elements:
- A measurement program as described within the ACP.
- A system to track qualifying nuclear material within D1203 and D2580.
- A system to train staff to ensure they are suitably qualified and experienced (SQEP) to fulfil safeguards roles.
- A system to identify and report incidents.
Based on the discussions with relevant staff, review of associated procedures, and review of training records I judge that Dounreay are adequately tracking nuclear material within QDR4, have s system in place to identify and report incidents, and are implementing the arrangements described in their ACP as required by NSR19 Regulations 6, 7, 9, and 17.
I provided five pieces of regulatory advice but none of these represented a shortfall against NSR19 requiring a new regulatory issue.
No observations were raised as part of the inspection.
Conclusion
Based on the discussions with staff, plant walkdown, the evidence sampled, I judge that Dounreay are able to adequately track qualifying nuclear material (QNM) within QDR4, are adequately implementing their arrangements for incident identification and notification, performing measurements, tracking nuclear material, and ensuring staff are SQEP in line with their corporate and building specific ACP within the Uranium Conversion Plant and the Fissile Material Store. The implementation of these arrangements is supporting the accountancy and control of QNM in-line with regulatory expectations and are compliant with the NSR19 regulations 6, 7, 9, and 17.
Upon consideration of the ONR guidance on inspection ratings, I judge that a rating of GREEN (no formal action) is appropriate.