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 examined DRDL’s arrangements made under Licence Conditions (LC) 23 (Operating Rules) and 24 (Operating Instructions) and their implementation. In addition, I attended a meeting to gather information related to an incident notified to ONR under LC7.
The inspection commenced with DRDL personnel providing a brief overview of their arrangements and results from their gap analysis against relevant good practice, followed by examining operating rules and their implementation through operating instructions.
We found that the management arrangements for LC23 in the main meet regulatory recommendations, with respect to hierarchy of limits and conditions, and are clearly derived from relevant safety functions. We recognise these arrangements have been applied only to the recently modified safety case PSC290 and are yet to be applied to existing safety cases across the site. We found that the Operating Rule wording was ambiguous in some cases we examined, and that in these instances the limits and condition were defined in the Identified Operating Instruction.
The licensee’s LC24 compliance arrangements meet ONR’s guidance, with respect to the provision of written instructions to carry out operations which may affect safety, including the implementation of safety case limits and conditions. There are specific procedural weaknesses relating to preparation, review and amendment of operating instructions which may be causing confusion with users and therefore compliance issues.
We made further enquiries regarding an incident previously notified to ONR, the investigation had been completed by the licensee and the learning identified is being applied.
In relation to the LC23 compliance inspection, I judged the licensee’s arrangements and their implementation to be adequate, meeting relevant guidance, there were some opportunities for improvement noted and shared with the licensee but no significant weaknesses were identified.
In relation to LC24 compliance inspection, I judged that the licensee’s arrangements and their implementation is below standard. The extant regulatory issue has been updated and the findings shared with the licensee. I will seek assurance that the areas for improvement are being addressed through the Nuclear Safety Improvement Programme (NSIP).