Executive summary
Date(s) of inspection: January 2024
Aim of inspection
The aim of the inspection is to undertake a regulatory compliance inspection against all duties imposed by the Fire (Scotland) Act 2005 to ensure that the licensee is compliant in respect of the premises: Specifically, to provide assurance that the Licensee’s arrangements associated with all applicable articles are suitable and adequate, and that the licensee is working to those arrangements.
Subject(s) of inspection
- Fire (Life Safety) Compliance Inspection - Rating: Amber
- Fire (Scotland) Act 2005 - Rating: Amber
Key findings, inspector's opinions and reasons for judgement made
This inspection assessed Nuclear Restoration Services (NRS) - Dounreay’s arrangements to support Life Fire Safety (LFS) and sampled the implementation of those measures on site. Compliance was assessed using relevant Office for Nuclear Regulation (ONR) inspection guidance, specifically Technical Inspection Guide (TIG) NS-INSP-GD-073 Issue 2 – The Regulation of Life Fire Safety Provision on GB Nuclear Sites. The inspection consisted of examination of the licensee’s arrangements regarding LFS covering the DFR Reactor Complex, the D1200 Labs facility and the DCP Store Extension project (walkdowns) as well as meetings to assess the implementation of and management of LFS at a site level.
It was noted that the Fire Risk Assessments (FRA) sampled as part of the inspection were of an adequate quality and level of rigor with a clear focus on driving improvements. The maintenance process for fire systems was inspected and found to be adequate with an area of good practice noted for the availability and functionality of the site's maintenance system (Mainsaver). Maintenance records for a variety of systems were sampled and found to be complete this included sampled equipment maintained by the Dounreay Fire & Rescue Service (DFARS).
No significant shortfalls were identified during the facility walkdowns and each area was found to be in an adequate condition. Regulatory advice was provided on some minor points related to the marking of fire doors and the sealing of small penetrations in fire compartment lines.
Training records for DFARS were sampled and it was reported that the DFARS incident commanders are currently operating without current incident command validation. A Level 4 Regulatory Issue will be raised to track the resolution of this shortfall.
The sites compliance with the Dangerous Substances & Explosive Atmospheres Regulations were discussed in the context of Regulations 6, 11 and 15 of the Fire Safety (Scotland) Regulations 2006. It was found that the site did not currently have a process in place for compliance with the DSEAR regulations and that they could not provide assurances that shortfalls did not exist with respect to the controls of dangerous substances. This shortfall will be considered via ONR’s enforcement management process.
Conclusion
Based on the evidence provided by NRS (Dounreay) and observed during the inspection, I consider that generally Dounreay have an adequate process in place for most aspects of the control and management of fire safety with respect to life safety. I judge that the fire risk assessments received are of an adequate quality and level of rigour and demonstrate a desire to drive continuous improvement through the raising of recommendations. This is supported by evidence of recommendations being closed out or otherwise actioned.
Additionally, the process for the maintenance of fire systems on site appears to be robust and it is my judgement that the site has made significant improvements to the understanding of fire alarm detection systems obsolescence. The implementation of the updated Mainsaver system and in particular the searchability and link to critical spares information is, in my judgement, an area of good practice.
Records sampled during the inspection were readily available and generally of an adequate quality. I judge that this demonstrates adequate fire safety management with only a single exception being identified related to incident command training. A Level 4 regulatory issue will therefore be raised to track the completion of appropriate training.
Despite the generally positive view of fire safety noted above, a significant shortfall was identified related to the understanding, assessment and control of sources of dangerous substances on site as required by the Fire Safety (Scotland) Regulations 2006. It is my judgement that Dounreay do not currently understand the totality of risk presented by dangerous substances on site and therefore cannot provide adequate assurance as to the safety of personnel on site. This shortfall will be considered via ONR’s enforcement management process.
In line with ONR inspection guidance I judge that an overall rating of Amber ‘Seek Improvement’ is appropriate as Dounreay could not demonstrate that they had assessed and controlled sources of dangerous substances on site as required by the Fire Safety (Scotland) Regulations 2006. Further considerations will now take place to determine what regulatory action is required to ensure the site returns to compliance.