Compliant decommissioning at Dounreay means meeting unyielding standards with GRC system flexibility
The UK Atomic Energy Authority was formed in 1954 when the British Government set up a new body to oversee the nation's nuclear research programme. However, the role of the group has evolved and today it has become a world leader both in decommissioning and regenerating nuclear sites and in developing fusion as a sustainable, secure and carbon-free energy source.
By the time the Prototype Fast Reactor closed at Dounreay in 1994, UKAEA had already turned its attention to this new task; by concentrating on the restoration of the environment at its sites as reactors finished operating. Since then, UKAEA has made extensive progress, and in 2005 they safely dismantled their fifteenth reactor, ZEBRA, at Winfrith.
In April 2005 the Nuclear Decommissioning Authority (NDA) was formed to take responsibility for the UK's civil nuclear clean-up programme. Dounreay Site Restoration Ltd, a wholly-owned subsidiary of UKAEA, is now a contractor to the NDA for management of decommissioning at Dounreay.
Between 1954 and 1994, Dounreay was the UK Centre of Fast Reactor Research and Development. At its peak the site had three reactors, reprocessing plants, fuel fabrication facilities, laboratories together with Intermediate Level and Low Level Waste facilities. In all, there were 180 facilities over 140 acres.
All research and development has now ceased at Dounreay and ownership of the site passed into the hands of the NDA (Nuclear Decommissioning Authority)
To date more than 100 facilities have been safely demolished and the clean-up scheduled to be completed by 2025 at an estimated cost of £2.5 billion. In all one in three local jobs depend directly or indirectly on the clean up.
With nuclear decommissioning on such a scale, regulatory compliance is mission critical and DSRL has to ensure compliance to all the regulatory demands and requirements of the two main governing bodies, the NII (the Nuclear Installation Inspectorate and SEPA (Scottish Environment Protection Agency).
In 2000 DSRL decided that it needed a compliance management system but the role was far broader than just straight forward document control. After a review of the market they chose a GRC (Governance Risk and Compliance) system AchieverPlus, from Sword Achiever.
AchieverPlus delivers a single point of access across all regulatory, quality and process resources in an organisation and provides a unique, management gateway that can easily be embedded into an organisation's existing processes without disrupting working practises. The system unifies all an organisation's disparate systems, standards, policies and resources across any number of sites and locations. Multiple areas of compliance can be included such as regulatory, legislative and best practice and encompass many industry standards.
AchieverPlus was chosen by DSRL for a number of reasons. It has been designed to be highly flexible and configurable. As DSRL knew they would need a system customised to their specific needs, AchieverPlus was felt to be "fit for purpose" and cost effective too. DSRL also needed support, end user training materials and the system's integration with email. Once up and running, the system was at the heart of DSRL's procedures.
Karen Wyatt, DSRL's "Achiever Controller and Developer" at Dounreay, took over from the original Achiever system manager, three and a half years ago. She is clear as to the significance of compliance at the site and the role AchieverPlus has to play in it, noting: "We use a customised version of AchieverPlus that ensures compliance for changes to safety case of the building areas. It governs any works that are going on in any of those buildings or any other change in the safety case. This means that the system is central to our procedures and far broader than just document control."
In total the site has to meet 36 licence conditions and AchieverPlus is at the heart of managing these. They include:
License Condition 6 - Documents, Records, Authorities and Certificates, states: "AchieverPlus must hold all documents pertaining to LC6 in a compliant manner."
License Condition 9 - Instructions to Persons on Site, states: "All instructions to anyone working on site are available on AchieverPlus."
License Condition 17 - Quality Assurance, states: "AchieverPlus is to keep us compliant with all relevant ISO standards."
Licence Condition 22 - Modification or Experiment on Existing Plant, specifies that: "By being Adaptable AchieverPlus provides a Modification System which is compliant with the requirement of the governing bodies."
Licence Condition 24 - relating to all Operating Instructions specifies that: "All operating instructions should be managed through AchieverPlus to ensure compliance."
Wyatt added: "All documents are held centrally and that all review comments are logged. The system allows for electronic signatures on the all important approvals required. There is a full audit trail of past and current issues and even obsolete documents are kept on the system."
Access levels are also critical in an organisation. The system maintains any protectively marked documents with a restricted view feature. AchieverPlus also prompts management to periodically review records to ensure that they do not go out of date. In addition, AchieverPlus functionality allows users to define keywords and to use these to set defaults when ensuring that information sent out only reaches the relevant controllers or owners of that information.
Different views provided by the system allow users to see information in role specific formats e.g. those suitable for Controllers, Owners or by Periodic Review Date, for example.
One especially important customisation of AchieverPlus was made to comply with LC22. The system's document control template was customised to provide a modification report database known as the "DMR" (Dounreay Modification Report system). This enables management to negate the risks associated with modifications to a safety case and categorises stakeholders, signatures and authority to proceed. By this means, all the processes with evidence of documentation are tied together before final approval is given.
In conclusion, therefore, DSRL needed to be compliant to the highest and most unyielding level.