Executive summary
Date(s) of inspection: January 2025
Aim of inspection
ONR nuclear safeguards inspectors will conduct a compliance inspection of Dounreay – Dounreay Division of Nuclear Restoration Services Limited during the week commencing 28th January 2025 focussing on waste characterisation and measurement control.
The purpose of this inspection is to seek evidence in support of Dounreay’s compliance with The Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19).
ONR will form regulatory judgements and provide a rating in line with ONR’s inspection rating guidance of Dounreay’s compliance against Regulation 7 & 9 and Schedule 2 of NSR19:
To form effective regulatory judgements on Dounreay’s compliance with the NSR19 regulations listed above, Inspectors will consider the ONR Guidance for the Assessment of Nuclear Material Accountancy, Control and Safeguards (ONMACS) guidance and the expectations within, with a particular focus on: FSE 6 and FSE 7.
Subject(s) of inspection
- FSE 6 Measurement Programme and Control - Rating: GREEN
- FSE 7 Nuclear Material Tracking - Rating: GREEN
- NSR19 Reg06 - Accountancy and control of qualifying nuclear material - Rating: GREEN
- NSR19 Reg09 - Operation of an accountancy and control plan - Rating: GREEN
- NSR19 Reg10 - Operating records - Rating: GREEN
Key findings, inspector's opinions and reasons for judgement made
The purpose of this planned inspection was to inform ONR's judgement regarding the adequacy of Dounreay (Dounreay Division of Nuclear Restoration Services (NRS) Limited) NMACS arrangements and implementation relating to waste characterisation and accountancy reporting to demonstrate compliance with the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19), Regulations 7 & 9 and 10. This inspection was targeted on waste characterisation as operating records of waste qualifying nuclear material showed an unreasonable level of implied accuracy, e.g. clean out waste drums recorded to 6dp of gramme.
As part of the inspection, I reviewed the operator's characterisation arrangements, measurement technical information, and conducted interviews with staff on characterisation and recording & reporting for Safeguards. The purpose of these activities was to gain assurance that Dounreay were implementing adequate arrangements, and these were reflected within the Accountancy & Control Plan (ACP). To inform my judgements on the adequacy of the arrangements and implementation of NMACS, I utilised the Safeguards Technical Assessment Guidance,SG-TAST-GD-001 iss. 4, (TAG), the Safeguards Technical Inspection Guidance,SG-INSP-GD-001 iss. 4,(TIG) and our safeguards expectations as described in the ONR guidance for Nuclear Material Accountancy, Control and Safeguards, ONR-CNSS-MAN-001 iss. 5, (ONMACS).
From my inspection sample I identified that the operating records and accountancy reports demonstrated adequate implied accuracy in line with expectations as described in ONMACS, relating to Regulations 6, 7 & 9. However, I also identified a minor shortfall against Regulation 12, with regard to timeliness of reporting of qualifying nuclear material (QNM) of items where prompt verification of estimated mass had been delayed. Additionally, the Dounreay Safeguards Team had not been explicitly listed as a Stakeholder for the characterisation fingerprint data review meetings, which I judged to be a minor shortfall against Regulation 6.
Utilising ONR’s inspection rating guidance, I have judged that a rating of GREEN is appropriate. Dounreay have accepted the inspection findings, and I have raised regulatory issues to monitor progress against the shortfalls identified.
Conclusion
This report presents the findings against Dounreay's arrangements and implementation of Nuclear Material Accountancy, Control & Safeguards (NMACS) in relation to waste characterisation and accountancy reporting.
I have judged that Dounreay arrangements and implementation meet relevant good practice (National Physical Laboratory Good Practice Guide No. 34 on Radiometric Non-Destructive Assay 2012, Safety Directors Forum (SDF) UK Nuclear Industry Guide to Clearance and Radiological Sentencing: Principles, Processes and Practices May 2017, and Nuclear Decommissioning Authority (NDA) Solid Radioactive Waste Characterisation Good Practice Guide March 2022) with regards to waste characterisation and recording of appropriate implied accuracy, which is described adequately within the current overarching ACP Claims 2.6, 2.6.1, 2.6.2 and 2.6.3. I also judged that Dounreay meet ONR's expectations, as described in ONR Nuclear Material Accountancy, Control and Safeguards assessment principles (ONMACS), with regards to the tracking of corrective knowledge relating to QNM records. Therefore, I have determined that with regard to waste characterisation and accountancy reporting, Dounreay is compliant in these regards with NSR19 Regulations 7, 9 & 10.
Considering proportional expectations with regards to NMACS, I judged that Dounreay have two minor shortfalls in relation to timeliness of accountancy reporting of QNM against ONR’s expectations, and by not identifying Safeguards as a stakeholder relating to the processes of characterisation of waste. Dounreay have accepted the inspection findings and I have raised regulatory issues to monitor progress against these two minor shortfalls.
Separately I also identified two shortfalls which do not meet my expectations, relating to use of a deminimis for accountancy reporting, and lack of clarity unique identity for batch items within accountancy records & reports. However, I am reserving judgement on these as they extend across the condition of the UK nuclear industry and require an agreed ONR Safeguards policy position, to ensure consistency. Therefore, I note these two shortfalls as Observations.
Utilising ONR’s inspection rating guidance, I have judged that a rating of GREEN is appropriate.