Office for Nuclear Regulation

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Devonport Royal Dockyard Limited LC22 & 23 Compliance Inspection

Executive summary

Purpose of Intervention

This intervention at the Devonport Royal Dockyard Limited (DRDL) licensed site was undertaken as part of the 2016/17 intervention plan and propulsion sub-programme strategy.

Interventions Carried Out by ONR

This inspection considered DRDL’s licence condition (LC) 22 (modifications on existing plant) compliance arrangements and examined the implementation of DRDL’s LC23 (operating rules). The LCs were inspected using ONR’s relevant technical inspection guides (TIGs).

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable.

Key Findings, Inspector's Opinions and Reasons for Judgements Made

The LC22 compliance inspection found that:

I considered that improvements should be sought from DRDL on implementing all of the requirements of the Change Record (CR) process and close out the CR processes in a timely manner once the modification has been implemented on site.

The LC23 compliance inspection examined the implementation of DRDL’s LC23 arrangements for operating rules to inform progress against an extant regulatory issue. This inspection found that:

We found that when difficulties are encountered maintaining compliance with operating rules, the necessary improvements are not being implemented in a timely manner.

Potential shortfalls in how operating rules are defined and implemented within the 15 Dock safety case (PSC-220) were identified. Insufficient information was available during our inspection to make a firm judgement in this area. Further documentation has now been provided which will be reviewed to inform further regulatory engagement.

Conclusion of Intervention

I rated DRDL's arrangements to control modifications to existing plant in line with the requirements of LC22 to be adequate, with one area for improvement.

I judge that the licensee’s approach to the identification and implementation of operating rules falls below the expected standard as outlined in the relevant TIG with some significant weaknesses being identified in the implementation of safety case requirements. It is noted that the licensee is currently implementing a programme of improvements associated with LC23 this will be monitored via an extant regulatory issue.