I undertook inspections at facility level and other work in accordance with the DSRL inspection plan for 2014/5, with the intention of providing evidence that DSRL is controlling its hazards properly and is compliant with its statutory obligations.
I carried out interventions at PFR and DFR against the requirements of Licence Conditions 22 and 28 to establish compliance. I carried out a review of the overall reactors decommissioning programme following the ASFL discussions to determine compliance against the requirements of Licence Condition 35.
My inspection against the requirements of licence condition 22 was undertaken to provide evidence that the licensee had made and was implementing adequate arrangements to control any modification on existing plant, and to determine the existence of a clear link to subsequent implementation on plant by means of method statements. My inspection provided evidence that general implementation of modifications is not fully adequate at DFR and PFR, and has the potential for the introduction of errors leading to operators working outside the scope of modifications.
My inspection against the requirements of licence condition 28 provided evidence at DFR and PFR that in general maintenance of plant that may affect safety is completed within the required timescales, and to the required standard. However, at PFR I observed some poor practice associated with the completion of maintenance of plant, which the licensee has agreed to correct.
I discussed the scope of the temporary improvements to safety that ONR require before agreeing to the limited restart of Alkali Metal retrieval activities to permit the completion of tanks 3 and 4 at PFR. I agreed to discuss the licensee’s formal proposals at my scheduled visit in December 2014.
The intervention identified regulatory concerns relating to the licensee’s arrangements for controlling modifications to existing plant. Although I consider that these findings and the actions required to be taken to resolve them fall within the scope of the recent Improvement Notice (I/2014/ONR/SH/001, 2014/415913) I intend to inform the licensee of my concerns by means of a letter. I identified specific aspects relating to the management of maintenance, which the licensee agreed to correct and I will follow up during my December 2014 visit.