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 2016/17.
As part of this intervention ONR inspectors examined DRDL’s Licence Condition (LC) arrangements for connecting and keeping in good working order safety mechanisms, devices and circuits (LC27) and for Examination, Inspection, Maintenance and Testing (LC28) and checked implementation. I also held Plant Management, 14 Dock Reactor Access House and conduct of operations meetings.
The LC 27/28 compliance inspection commenced with an opening meeting to determine the areas ONR would target. The safety related systems which ONR decided to examine were the compressed gas and dock-side emergency diesel generator systems. Examining aspects of the safety case, plant maintenance schedules and conducting a follow-up on a diesel generator hose modification following a breakdown.
The Licensee is making the necessary changes to its arrangements to enhance the links between the safety case and identified safety mechanisms, devices and circuits. ONR will track the implementation aspect of the enhancements to ensure they align with ONR’s expectations. A regulatory issue already exists to manage the shortfalls relating to this finding.
Based on the inspection, we confirmed that maintenance activities align with the safety case requirements. We also found that the control of pressure equipment and the periodicity for examination and testing was well defined.
A number of observations were identified relating to having written arrangements for use of hoses beyond the inspection date. Also observations relating to the structure and format of instructions to further aid operations and maintenance personnel when conducting routine activities.
Progress meetings were held with 9 dock plant management, 14 Dock Reactor Access House project and the business improvement team. No significant concerns were identified and updates were provided on key performance areas and permissioning activities.
In relation to the LC27 compliance inspection, I judge the Licensee’s arrangements to be in need of further improvement. ONR will track progress against an existing regulatory issue associated with the implementation of enhancements of their LC27 process. I noted however improvement to DRDL LC27 arrangements are underway and are expected to be delivered early 2017.
In relation to the LC28 compliance inspection, I judge that the Licensee’s arrangements and their implementation to be adequate. Some opportunities for improvement were identified and shared with the Licensee but no significant weaknesses were identified.