Executive summary
Date(s) of inspection:
- January 2025
Aim of inspection
Judge the licensee's compliance with LC 35 (Decommissioning), which requires them to make and implement adequate arrangements for the decommissioning of any plant or process which may affect safety, and for the production and implementation of decommissioning programmes for each plant.
Gain evidence for closure of RI-10876 (Absence of Credible Site and Facility Decommissioning Plans) Action 2: "Dounreay to demonstrate to ONR that they have developed and implemented adequate arrangements for the development, management and governance of the site LTP and associated NTWP."
Subject(s) of inspection
- LC35 - Decommissioning - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
Dounreay’s high-level decommissioning strategy is to develop known solutions to decommissioning challenges with a focus on high hazard risk reduction, in line with NDA’s strategy. The site is subject to NDA’s spending review and sanction processes and has produced a business case to justify the proposed delivery approach. The Lifetime Plan (LTP) and business case together provide a more realistic decommissioning programme than under the previous Parent Body Organisation model, with appropriate milestones and timeframe for reaching the ‘interim end state’.
The LTP and strategy flows down through the three programmes to the facility level, with staff having deep knowledge of the scope and schedule of work required to deliver the LTP in their respective programmes. Decommissioning plans for individual buildings are at varying level of maturity and Dounreay is yet to document strategies for programme level prioritisation of decommissioning activities as the site has recently transitioned to a programmatic way of working, but considerable progress has been made since the previous LC35 inspection. Adequate governance is applied to the LTP and change control is suitably managed through the Programme Boards and the Portfolio Boards, allowing escalations, reprioritisation and management of resource.
Dounreay has not yet decided whether it will adopt NRS’ LC35 compliance arrangements, therefore, its management system lacks a single LC35 compliance document setting the decommissioning arrangements required by this LC. However, I expect this can be produced with relative ease using information from suite of documentation sampled such as the site strategy, LTP, business case, and facility decommissioning plans.
Conclusion
Dounreay has made improvements in LC35 compliance since the previous LC35 inspection by developing a credible LTP and associated 4-year rolling near-term work plan. I gained confidence through discussions with various staff within each of the programmes that work in those programmes is being planned and carried out in accordance with the LTP and the associated governance and change control processes. I consider the programmatic approach to be suitable for implementing the LTP, however, I judge there to currently be an absence of documented programme level decommissioning strategies, noting this is under development for the Reactors programme.
Dounreay does not have a single LC35 compliance document at a site level, which is a shortfall against LC35, however, I do not consider this to be currently adversely impacting the site and much of the information that would comprise such a document may be found across various other documents.
Overall, I am satisfied that the site has a suitable decommissioning strategy and LTP which are being implemented across the three programmes and I expect the adequate improvement can be made against the identified shortfalls by raising Level 4 Regulatory Issues. Therefore, I am applying a ‘green’ rating to this inspection.
I judged there to be sufficient evidence to close out Action 2 (LTP & NTWP Governance Arrangements) of RI-10876 (Absence of Credible Site and Facility Decommissioning Plans).