Executive summary
Date(s) of inspection:
March 2025
Aim of inspection
ONR nuclear safeguards inspectors conducted a physical inventory take (PIT) evaluation focussed compliance inspection of the D2580 Fissile Material Store and D1231 Special Nuclear Materials Store within the Material Balance Area (MBA) QDR4, DN060 Clearance, Waste Assessment, Decontamination and Segregation within MBA QDR6 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 NRS Dounreay’s compliance against the following Regulations in NSR19 Regulations 6, 7, 12, and 15.
To form effective regulatory judgements on NRS 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.
Subject(s) of inspection
- FSE 7 Nuclear Material Tracking - Rating: GREEN
- FSE 9 Material Balance - Rating: GREEN
- NSR19 Reg06 - Accountancy and control of qualifying nuclear material - Rating: GREEN
- NSR19 Reg07 - Accountancy and control plan - Rating: GREEN
- NSR19 Reg12 - Accounting reports - Rating: GREEN
- NSR19 Reg15 - Material balance report and physical inventory listing - Rating: GREEN
Key findings, inspector's opinions and reasons for judgement made
In accordance with the ONR Integrated Inspection Strategy (IIS) for Nuclear Restoration Services (NRS) Dounreay, ONR Safeguards conducts Safeguards compliance inspections at the NRS Dounreay site. For this intervention, D2580 Fissile Material Store and D1231 Special Nuclear Materials Store within the Material Balance Area (MBA) QDR4, DN060 Clearance, Waste Assessment, Decontamination and Segregation within MBA QDR6 were selected. Two pieces of regulatory intelligence informed the proposed scope of this inspection. The first, NRS 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 Physical Inventory Take (PIT) procedures over the course of 2024-2025.
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 NRS 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 adequacy of item sampling arrangements as part of the PIT in relation to NSR19 regulation 10 (1e). A single level four regulatory issue has been raised to address this shortfall.
I provided eight pieces of regulatory advice relating to consolidation of material, use of seals, minor procedural updates, review of manual handling and working at height activities, and updates to material item descriptions on ATOM. One observation was raised as part of this inspection, two ladders were missed from previous annual inspections.
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 NRS Dounreay are adequately performing a PIT within QDR4 and QDR6 required by NSR19 Regulations 6, 7, 12, and 15 and FSEs 7 Nuclear Material Tracking and 9 Material Balance.
Conclusion
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 QDR4 and QDR6. 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. Regulatory advice provided during this inspection will be followed up as part of routine regulatory activities.
Upon consideration of the ONR guidance on inspection ratings, I judge that a rating of GREEN (no formal action) is appropriate.