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 Licence Condition (LC) arrangements for connecting and keeping in good working order safety mechanisms, devices and circuits (LC27) and for maintenance (LC28) and checked implementation. I also held a Plant Management Level 4 meeting and a Radioactive Waste Level 4 meeting.
The LC27/28 compliance inspection commenced with DRDL providing a brief overview of their arrangements, this was followed by examining aspects of the safety case, plant maintenance schedules and reviewing maintenance records. The safety related systems sampled were Dockside Cranes and Dock Flood Alarm System.
The licensee’s arrangements do not make any distinction, within the safety related category, to identify what plant and equipment is required to act in response to a fault condition to prevent or mitigate a radiological consequence, and there is no method of identifying these on plant.
Based upon the inspection sample, we confirmed that maintenance activities undertaken do align with safety case requirements. We also found maintenance activities are being carried out by competent persons in accordance with authorised instructions.
We made a number of observations related to recording practices and instruction structure and layout, confirming further improvements are required with respect to operating instructions.
Level 4 meetings held with the SRC Plant Management and Radioactive Waste Management did not identify any significant safety concerns, updates were provided on key performance areas and permissioning activities.
In relation to the LC27 compliance inspection, I judge the licensee’s arrangements and their implementation to be below standard. A regulatory issue has been raised and the findings shared with the licensee.In relation to the LC28 compliance inspection, I judge that the licensee’s arrangements and their implementation is adequate, meeting relevant guidance. There were some opportunities for improvement noted and shared with the licensee but no significant weaknesses were identified.