Date(s) of inspection:
- October 2022
Aim of inspection
In accordance with the Office for Nuclear Regulation’s (ONR’s) Strategy, each year ONR performs a series of planned compliance inspections of selected licence conditions, targeted at those facilities with significant importance to nuclear safety. The aim of this inspection was to inspect Dounreay Site Restoration Limited’s compliance with a number of Licence Conditions and the Lifting Operations and Lifting Equipment Regulations 1998 within the thematic area of crane/lifting operations.
Subject(s) of inspection
- LC10 – Training – Rating: Green
- LC23 – Operating rules – Rating: Green
- LC24 – Operating instructions – Rating: Green
- LC28 – Examination, inspection, maintenance and testing – Rating: Green
Key findings, inspector’s opinions and reasons for judgement made
This report records the findings of my inspection of Dounreay Site Restoration Limited’s compliance with a number of Licence Conditions and statutory requirements within the thematic area of crane/lifting operations. I inspected the records produced and held by Dounreay Site Restoration Limited, undertook a walkdown of two facilities, and witnessed two lifts.
I carried out this inspection against the requirements of the following Site Licence Conditions:
- LC23 Operating Rules
- LC24 Operating Instructions
- LC28 Examination, Inspection, Maintenance and Testing
- LC10 Training
I carried out this inspection against the requirements of the following Relevant Statutory Provisions:
- Lifting Operations Lifting Equipment Regulations (LOLER) 1998.LOLER
Overall, I consider that lifting operations are well controlled, with a clear link to the safety case requirements. I consider the shortfalls I identified to be relatively minor and do not compromise nuclear safety. I have assigned a rating of Green – No Formal Action for this inspection
LC23 Operating Rules
Based on my sample, I was content that the operating rules derived from the safety case were appropriately understood and translated adequately into the site’s operating instructions.
LC24 Operating Instructions
The formation of a lifting and rigging team, and a number of appointed persons lifting (APL’s) who write and produce the lift plans, has been a positive improvement to both conventional and nuclear safety.
Some facilities considered a standard lift equivalent to a basic lift, and other facilities considered standard equivalent to intermediate. I considered this to be a potential error trap, which did not meet my expectations given the length of time the new procedure had been in place.
I reviewed a number of lift plans. I consider that there is an over reliance on the experience of the operators, rather than embedding information within operating instructions. I have raised this as Regulatory Advice.
LC28 Examination, Inspection maintenance and Testing
DSRL is undertaking a gap analysis against modern standards. I consider this to be a positive improvement to nuclear safety. I was content that DSRL is currently reviewing the availability of spares in collaboration with the NDA estate.
I was content that DSRL is undertaking additional maintenance of its lifting equipment other than the statutory minimum, however, I consider that it would be beneficial to have a better understanding of the work the inspector was undertaking on the lifting equipment.
I was content that the building APL’s in PFR and D2001 had sufficient knowledge of lifts being undertaken within the building under their responsibility, and that they were suitably SQEP.
I discussed the central management of ensuring staff remain SQEP. I was content that safety related posts required renewal of training on a three yearly basis. I reviewed the training records of the ATO at the time of witnessing the lift, and a senior craft technician (mechanical). I was content that both individuals were SQEP to undertake the tasks, and that all training was in date.