Date(s) of inspection
- October 2023
Aim of inspection
The themed inspection will target radioactive waste management activities to gain assurance of Dounreay’s compliance with Licence Conditions (LC) 32, 34, 26, 12 and 10.
Subject(s) of inspection
- LC10 – Training – Rating: Green
- LC12 – Duly authorised and other suitably qualified and experienced persons – Rating: Green
- LC26 – Control and supervision of operations – Rating: Green
- LC32 – Accumulation of radioactive waste – Rating: Green
- LC34 – Leakage and escape of radioactive material and radioactive waste – Rating: Green
Key findings, inspector’s opinions and reasons for judgement made
This inspection examined compliance against a number of licence conditions (LCs) under the theme of radioactive waste management at the Dounreay site. The inspection considered how radioactive wastes are controlled and contained to avoid leakage and escape (LC34), how accumulations are minimised (LC32), control and supervision of activities associated with generation and handling of radioactive waste (LC26), training of staff (LC10) and ensuring only suitably qualified and experienced persons (SQEP) perform duties which may affect safety(LC12).
Dounreay demonstrated adequate arrangements and their implementation for LC34, with all liquid wastes stored in suitable tanks, vessels, or containers with appropriate secondary containment, and solid wastes in suitable containers with a suitable periodic inspection regime.
Dounreay demonstrated adequate arrangements for minimising the accumulation of radioactive waste in its current day to day operations, and for recording of waste so accumulated. However owing to ongoing issues associated with waste fingerprints which has resulted in accumulation of radioactive waste in several facilities, I considered there to be minor shortfalls to regulatory expectations in relation to LC32. Consequently, I raised a Level 4 Regulatory Issue (RI-11759) and a Regulatory Action requiring Dounreay to develop prioritised plans to deal with these wastes, and inform ONR of commencement of certain waste transfers.
Dounreay provided a good overview of its current waste team capability and capacity, and a projection of where it expects to be under the new programmatic organisational structure to be adopted imminently, including development of a waste career pathway. Waste operatives on plant were able to give clear and knowledgeable explanation of their roles, including control and supervision, on-the-job training and assessment of SQEP progression, and training records associated with key waste-related roles in D1204 were complete and in accordance with Dounreay’s arrangements.
Overall, all LC’s were rated as Green – Adequate with minor shortfalls noted against LC32 on the accumulation of legacy waste for which I have raised a Level 4 Regulatory Issue requiring site to develop a prioritised plan to dispose of the wastes.
On the basis of the evidence sampled in the areas targeted, I judge that Dounreay demonstrated adequate compliance against each of the LCs inspected, notwithstanding the minor shortfalls to regulatory expectations under LC32 which will be addressed via Regulatory Issue RI-11759.
Therefore, I consider a rating of Green (no formal action required) is merited for each LC inspected.