This intervention, at the Devonport site, was undertaken as part of a series of planned interventions supporting ONR's DRDL Intervention Strategy and plans for 2015/16.
As part of this intervention I held a number of meetings with the licensee to discuss current operations, regulatory actions and future activities needing ONR permission. In addition, I conducted a joint inspection with DNSR representatives, supported by ONR Human Factor Specialist Inspectors, examining the adequacy of the management arrangements for controlling the safety of operation of mobile cranes.
The safety management arrangements controlling mobile crane operations on 5 Basin Arm were examined. The inspection commenced with DRDL providing a brief overview of their arrangements, followed by observing crane set-up and examination of evidence packs. Based upon the interactions with crane operators, we found they had a good understanding of the safety management arrangements and the Dockside Manager and Plant Operations Coordinator demonstrated a good level of understanding of the safety case requirements and necessary control measures.
We found that the safety management arrangements included a sufficient number of verification and hold-points, and the accompanying evidence packs sampled were complete and legible. However, we found that a graded approach has not been applied to the key control system and aspects of the Plant Operations Procedures do not meet the current expectations of operating instructions with respect to demonstrating positive compliance with limits and conditions.
Based upon the evidence presented on the safety management arrangements supporting the 3050 Mobile Crane, and considering that DRDL has conducted trials to support the implementation of 4100 Mobile Crane use, and intends to conduct further trials as part of the Plant Management Hold Point Plan, ONR did not identify any matters that would preclude the use of 4100 Mobile crane on 5 Basin Arm for the purposes of the V class activities.
Meetings were held to discuss DRDL’s progress against regulatory issues and actions and ONR assessment recommendations. In all cases DRDL is actively seeking clarification on what is required therefore resolution can be achieved. DRDL is intending to improve visibility of action status by capturing the details within the company action tracking system. ONR will continue to engage with DRDL to monitor progress.
I made further enquiries regarding two incidents previously notified to ONR, in one case the investigation had been completed and the learning identified is being applied. Investigation into the second incident was not complete and based upon the information provided it appears that suitable corrective measures have been identified and some implemented.
In relation to the adequacy and implementation of LC23 and LC24 arrangements in relation to safe operation of mobile cranes, I judge that whilst the fundamental requirements are met there are some procedural weaknesses and failures in implementation. No matters were identified that would preclude safe use of the mobile cranes or which could significantly affect nuclear safety. I have raised an action to be tracked to completion through the regulatory issue database and I will seek assurance that the areas for improvement are being addressed through the Nuclear Safety Improvement Programme (NSIP).