Dounreay - Inspection ID: 53193

ONR nuclear safeguards inspectors conducted a physical inventory take (PIT) evaluation focussed compliance inspection of the Dounreay prototype fast reactor (PFR) within the Material Balance Area (MBA) QDR1 as well as any facilities deemed relevant to the inspection, The purpose of this inspection was to seek evidence in support of Dounreay’s compliance with The Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19). 
 
ONR formed regulatory judgements and provided a rating in line with ONR’s inspection rating guidance of Dounreay’s compliance against the following Regulations in NSR19 Regulations 6, 7, 12, and 15. 
  

To form effective regulatory judgements on Dounreay’s compliance with the NSR19 regulations listed above, inspectors considered the ONR Nuclear Material Accountancy, Control and Safeguards Assessment Principles (ONMACS) and the expectations within. There was a particular focus on FSE’s 7 and 9. 

In accordance with the ONR Integrated Inspection Strategy (IIS) 2024/25 for Dounreay, ONR Safeguards conducts Safeguards compliance inspections at the Dounreay site. One such intervention was performed to inspect Dounreay’s compliance with the requirements of NSR19 in relation to nuclear material accountancy of the Dounreay PFR. For this intervention, the MBA known as QDR1 PFR was selected.  Two pieces of regulatory intelligence informed the proposed scope of this inspection. The first, Dounreay have recently reported an issue in discrepancies between plant and the ATOM system resulting in misreporting information to ONR. The second, ONR has identified multiple shortfalls in relation to PIT procedures over the course of 2023-2024.

This inspection sought to collect evidence of arrangements and their implementation to make judgements of compliance against NSR19 Regulations 6, 7, 12, 15.  The inspection comprised of discussions with staff, review of accountancy systems, and reviews of associated procedures, operating and accounting records.    

The inspection targeted the operator’s procedures for conducting a PIT. This involved an evaluation of the operator's conduct in preparation and during the PIT as well as the adequacy of their PIT procedures. 

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).   

Based on the sample I inspected, I judge that Dounreay has adequately implemented the following elements of a PIT of qualifying nuclear material;    

• Implementation of local arrangements as outlined in regulations 6 and 15 and as described in the Accountancy and Control Plan (ACP) for the PIT.
• An ACP that provides adequate descriptions of the associated PIT procedures in line with regulation 7.
• Production of accounting reports provided to the ONR under regulation 12 that are traceable and accurate to the supporting source documentation. 
   

I identified a single minor shortfall against the implementation of arrangements as part of PIT activities. This shortfall was in relation to NSR19 regulation 9. (1) Implementation of arrangements as described in the ACP. A single regulatory issue has been raised to address this shortfall.

I provided six pieces of regulatory advice relating to procedural updates, ACP updates, and conduct of staff during the PIT. I raised two minor observations surrounding sampling methodology and superfluous wording within procedures.  

Based on my review of operator implementation of PIT procedures, operating records, and accountancy reports, as well as discussions with relevant staff; I judge that Dounreay are adequately performing a PIT within QDR1 required by NSR19 Regulations 6, 7, 12, and 15 and FSEs 7 Nuclear Material Tracking and 9 Material Balance.

Based on the sample inspected, I judge that Dounreay are adequately implementing procedures and are producing adequate operator records, accountancy records, and accountancy reports as part of a PIT within QDR1 PFR. The implementation of these arrangements is supporting the accountancy and control of QNM in-line with regulatory expectations FSE7 and FSE9 and are compliant with regulations 6, 7, 12, and 15 of NSR19. 

A single regulatory issue has been raised to address a minor shortfall.

Upon consideration of the ONR guidance on inspection ratings, I judge that a rating of GREEN (no formal action) is appropriate.