Executive summary
Date(s) of inspection:
- August 2024
Aim of inspection
ONR nuclear safeguards inspectors conducted an inspection at Dounreay (Dounreay Division of Nuclear Restoration Services Limited) to provide assurance that nuclear material accountancy, control, and safeguards (NMACS), in relation to corporate structure, training, and resilience were being adequately captured within the Accountancy and Control Plan (ACP) and implemented.
Subject(s) of inspection
- FSE 1 Leadership and Management for NMACS - Rating: GREEN
- FSE 3 Competence Management - Rating: AMBER
- FSE 5 Reliability, Resilience and Sustainability - Rating: GREEN
- NSR19 Reg07 - Accountancy and control plan - Rating: AMBER
- NSR19 Reg09 - Operation of an accountancy and control plan - 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 to demonstrate compliance with the Nuclear Safeguards (EU Exit) Regulations 2019 (NSR19), Regulations 7 and 9. This inspection was targeted as Dounreay has undergone a major corporate restructure post NRS ownership; . has had previous inspection findings relating to lack of training for staff in Safeguards related roles; and as there has been a recent handover in the responsibilities for ownership of the Accountancy and Control Plan (ACP) and Basic Technical Characteristic (BTC) for facilities.
As part of the inspection I reviewed the operator's training records, conducted interviews with staff on Safeguards training and policy, and conducted interviews with staff on the Safeguards organisational structure. The purpose of these activities was to gain assurance that Dounreay were implementing adequate arrangements and these were reflected within the ACP. To inform my judgements on the adequacy of the arrangements and implementation of NMACS, I utilised the Safeguards Technical Assessment Guidance (TAG), the Safeguards Technical Inspection Guidance (TIG) and our safeguards expectations as described in the ONR guidance for Nuclear Material Accountancy, Control and Safeguards (ONMACS).
From my inspection sample I identified that Dounreay's organisational structure was robust and provided suitable resilience to deliver against its NMACS obligations. However, not all roles with Safeguards responsibilities and oversight have had adequate training or that NMACS responsibility was reflected in their role profiles. The ACP, which describes the operators arrangements, did not adequately reflect the reality of the organisational structure, training, or resilience arrangements utilised by the operator.
I judged that Dounreay had significant shortfalls in relation to competency management good practice and that the legal requirement of NSR19 regulation 7 was not met as it did not reflect the accounting and control system that is in place.
Utilising ONR’s inspection rating guidance, I have judged that a rating of Amber is appropriate. Dounreay have accepted the inspection findings and I will raise a regulatory issue to monitor progress against the shortfalls identified.
Conclusion
This report presents the findings against Dounreay's implementation of procedures related to leadership and management, competence management, and reliability, resilience, and sustainability; as well as the reflection of these arrangements within the ACP.
I have judged that Dounreay arrangements and implementation, of Leadership and Management for NMACS aligns with good practice; their NMACS regime meets good practice in relation to it’s Reliability, Resilience and Sustainability and the site is compliant with NSR19 regulation 9.
I judged that Dounreay had significant shortfalls in relation to competency management good practice and that the legal requirement of NSR19 regulation 7 was not met as it did not reflect the accounting and control system that is in place.
Utilising ONR’s inspection rating guidance, I have judged that a rating of Amber is appropriate. Dounreay have accepted the inspection findings and I will raise a regulatory issue to monitor progress against the shortfalls identified.