Office for Nuclear Regulation

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System based inspection (SBI) of the Dock 9 - Internal impact

Executive summary

Purpose of intervention

In accordance with Devonport Royal Dockyard Limited (DRDL) 2016/17 intervention plan, a system based inspection (SBI) of the Dock 9 – Internal impact, RAH crane and reactor compartment lift system was undertaken on site.  The purpose of this inspection was to confirm the adequacy of implementation of the licensee’s safety case claims in respect of this system.

Interventions Carried Out by ONR

ONR Inspectors examined evidence of the adequate implementation of licence conditions: LC10 (Training), LC23 (Operating rules), LC24 (Operating instructions), LC27 (Safety mechanisms), LC28 (Maintenance EMIT) and LC34 (Leakage and escape of radioactive material and radioactive waste).

The inspection comprised of discussions with DRDL staff, a plant walk-down and reviews of plant records and other documentation. We examined the implementation of key safety measures claimed in the safety case, to verify if these were effective on the plant, and to confirm if adequate maintenance and training are carried out to support its safe operation.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable.

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

From the evidence examined during this inspection, we consider that DRDL has implemented adequately, those claims within the facility safety case that relate to internal impact, RAH crane and reactor compartment lift system. DRDL was able to demonstrate an adequate understanding of the limits and conditions necessary in the interest of safety in respect of the system.

ONR did, however, identify a number of areas for improvement relating to the inconsistency of the implementation of operating instructions and the adequacy of the review processes relating to the EMIT and maintenance schedules.

DRDL was not able to demonstrate a consistent approach in relation to ensuring that all operations which may affect safety are adequately carried out in accordance with written instructions. DRDL was also not able to demonstrate the timely review of the EMIT and maintenance schedules. However, the plant inspected gave no cause for concern over condition or functionality and there was no apparent deterioration or degradation that was not being effectively managed. We judged that the containment of radioactive material was adequately managed.

Conclusion of Intervention

We judge that the licensee has adequately implemented the relevant limits and conditions necessary in the interest of safety identified in its safety case. Furthermore we are content that the licensee’s arrangements with respect to detection, control and containment of radioactive materials are adequate.

We identified a number of areas for improvement in respect of arrangements made under LC24 and LC28. We provided initial feedback with respect to our findings, which the licensee acknowledged. ONR will review DRDL’s progress in these areas through future routine inspections.