Office for Nuclear Regulation

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BAE Systems Marine Limited (BAESML) – Devonshire Dock Complex - Planned Intervention

Executive summary

Purpose of intervention

This was a planned inspection at BAE Systems Marine Limited’s (BAESML’s) Devonshire Dock Complex (DDC) licensed nuclear site at Barrow, undertaken as part of the planned intervention strategy for the DDC site for 2015/16.

Interventions Carried Out by ONR

A System Based Inspection (SBI) was undertaken jointly with DNSR in the area of “Nuclear Lifting and Handling”, referred to as S4.4, at the DDC.  The objectives of a SBI are to confirm that the relevant safety systems and structures are able to meet the safety functional requirements defined in the safety case and to check implementation of the Licence Condition (LC) arrangements for:  LCs 10 (training); 23 (operating rules); 24 (operating instructions); 27 (safety mechanisms, devices and circuits); 28 (examination, inspection, maintenance and testing); 34 (leakage and escape of radioactive material and radioactive waste).

I undertook planned information gathering.  This included:

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable since our overall judgement was that the system/ structure adequately fulfils the requirements of the safety case.

Key Findings, Inspector's Opinions and Reasons for Judgements Made

We identified two matters that were generic in that that they applied to several safety functional requirements and/ or several LCs.  These were that:  no definition was in place of lifts that may affect nuclear safety; and, there was a lack of evidence of compliance with conditions and limits necessary in the interests of safety during historical lifts.  The first matter applied to LCs 10, 23 and 24 whilst the second applied to LCs 23 and 24.  I raised a single ONR compliance issue to cover both these matters.  Although both matters cover several LCs, the most significant impact of both matters relates to LC23.  This is taken into account in my discussion and rating of each LC.

In relation to the LC10 element of the SBI, we identified several positive items including:  linking the ability to operate a crane to the training record of an operator; crane operating modular training; the inclusion of lifting teams in pre-core load training; and, arrangements are in place for ensuring appropriate qualifications, training and expertise of contractor staff allocated to nuclear lifting and handling work.  As noted earlier a generic matter was raised relating to there being no definition in place of lifts that may affect nuclear safety.  This generic matter affects LC10.  Taking these factors into account, I judged the inspection of arrangements for LC10 to be adequate.

In relation to the LC23 aspects of the SBI, we identified several positive items including:  a clear link between the relevant safety cases and the operating rules which are the conditions and limits necessary in the interests of safety; provision of evidence to support the crane seismic capability claimed in the safety case; and, control of lifting operations at the Wet Dock Quay by the Reactor Test Group.  As noted earlier generic matters were raised relating to:  there being no definition in place of lifts that may affect nuclear safety; and, a lack of evidence of compliance with operating rules during historical lifts.  Although both matters cover several LCs, the most significant impact of these matters relates to LC23.  As noted earlier I raised a single ONR compliance issue to cover both these matters.  Taking these factors into account, I judged the arrangements inspected under LC23 to be below standard.

In relation to the LC24 element of the SBI, we identified several positive items including:  a clear link between the relevant safety cases and the operating instructions; clarity of sampled operating instructions, supported by discussions with operators; and, clarity of sampled maintenance instructions.  As noted earlier generic matters were raised relating to:  there being no definition in place of lifts that may affect nuclear safety; and, a lack of evidence of compliance with operating rules during historical lifts.  These generic matters affect LC24.  Taking these factors into account, I judged the arrangements made under LC24 to be adequate.

In relation to the LC27 element of the SBI, we reviewed BAESML’s definition of Safety Mechanisms, Devices and Circuits (SMDCs) and concluded that this definition is broadly consistent with ONR’s guidance.  BAESML has noted that there are no SMDCs associated with nuclear lifting and handling equipment. However, during the SBI we discussed “cruciform” limit switches and triggers in use for one of the cranes sampled and considered that a case could be made that these devices were SMDCs.  We agreed to consider this during a separate planned LC/AC27 compliance inspection.  This is appropriate, since the devices are in use and we confirmed that they are being maintained.  For these reasons, I have concluded that LC27 is not applicable to this system based inspection.

In relation to the LC28 element of the SBI, we identified several positive items including:  a clear link between the relevant safety cases and the maintenance programme;  clarity of the process in place for maintenance review and control of planned maintenance schedules;  adequate implementation of the maintenance review process for a sampled crane;  defects identified during maintenance are cleared quickly;  and, the good physical condition of two of the cranes sampled during plant walk-down.  Taking these factors into account, I judged the arrangements made under LC28 to be of a good standard.

In relation to the LC34 element of the SBI, we determined that there are no lifts of radioactive waste.  We also determined that there are lifts of solid radioactive material, but these are restricted to lifting sealed sources and large components in which no radioactive material is open to the environment.  For these reasons, I concluded that LC34 is not applicable to this system based inspection.

Conclusion of Intervention

Our overall judgement was that the systems and structures in place for controlling nuclear lifting and handling adequately fulfil the requirements of the safety case.

From the evidence gathered during this intervention, no matters have been identified that are likely to have a significant impact on nuclear safety on the site at this time.  Therefore, no further regulatory action arising from this visit is considered necessary.