This report covers an inspection of RRDL’s licensed site at Rosyth undertaken as part of a series of planned interventions in accordance with the IIS Strategy and Plan.
This site visit consisted of an inspection of the licensee’s compliance with Licence Conditions 11 (Emergency Arrangements), 12 (Duly Authorised and other Suitably Qualified and Experienced Persons), 23 (Operating Rules) and 24 (Operating Instructions).
The LC11 inspection undertaken was undertaken by two ONR inspectors and involved the observation of the partial re-demonstration of the on-site emergency response arrangements focusing on casualty recovery and procedures and protocols at the incident scene.
The LC12, LC23 and LC24 compliance inspections involved examination of relevant licensee documentation, targeted discussions with relevant members of the licensee’s staff and inspection of the Active Waste Accumulation Facility.
Additional to the Licence Condition compliance inspections, I undertook a routine update of issues that had been raised at previous site inspections, confirmed that the site has the necessary arrangements at Dock Number 2 in advance of the proposed Licence Variation, met with the site Safety Representatives and attended a routine Regulatory Interface Forum.
The LC11 Level 1 re-demonstration was based upon a loss of containment event occurring within the Active Waste Accumulation Facility, with 2 associated casualties. I considered that the scenario provided a suitably challenging test of the emergency arrangements. The exercise demonstrated adequate arrangements in relation to casualty recovery, communications and command and control at the incident scene. On this basis I have given an inspection rating of adequate. Self-evaluation by the Rosyth Royal Dockyard Limited internal assessment team demonstrated good alignment with observations and assessment by the regulators.
I held a periodic meeting with safety representatives, to support their function of representing employees and to receive information on matters affecting their health, safety and welfare at work. There were no issues arising from this meeting.
The compliance arrangements for LC12 and LC24 were found to be adequate on inspection and complied with the relevant ONR guidance. On this basis I have given an inspection rating of adequate for this inspection.
The LC23 inspection confirmed that the licensee’s approach focuses its safety management controls on the most important limits and conditions and that progress is being made in relation to the existing regulatory issue in relation to the requirement for a modern standards safety case. There was no clear audit trail from existing safety case documentation to the Operating Rules and subsequently to the Operating Instructions and no summary for the operators of the technical basis for each Operating Rule. On this basis I have given an inspection rating of below standard and a regulatory issue will be raised to address this shortfall.
The level 4 meeting reviewed progress against the existing issues on the ONR Issues database. On the basis of these discussions and evidence provided I am satisfied that adequate progress is being made on these issues.
Physical inspection confirmed that the site has the necessary arrangements at Dock Number 2 in advance of the proposed Licence Variation.
The Regulatory Interface Forum provided an opportunity for site and MoD representatives to provide an update to regulators. No issues arose from these discussions.
On the basis of the information provided and evidence obtained during this intervention, I concluded that the licensee has effective arrangements under Licence Conditions 11 (Emergency Arrangements), 12 (Duly Authorised and other Suitably Qualified and Experienced Persons), and 24 (Operating Instructions). A shortfall has been identified in the licensee arrangements for Licence Condition 23 (Operating Rules) in relation to the line of sight from the safety case documentation to the limits and conditions implemented within the facility and a regulatory issue will be raised to address this.