Office for Nuclear Regulation

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Devonport – LC23 Compliance Inspection

Executive summary

Purpose of Intervention

This intervention at the Devonport Royal Dockyard Limited (DRDL) licensed site was undertaken as part of the 2017/18 intervention plan and propulsion sub-programme strategy.

Interventions Carried Out by ONR

This inspection examined the implementation of DRDL’s LC23 Operating Rules (ORs) arrangements.  The LC was inspected using ONR’s relevant technical inspection guide (TIG).

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable.

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

The LC23 compliance inspection examined the implementation of DRDL’s LC23 arrangements for operating rules to inform progress against an extant regulatory issue and gave an ‘AMBER’ rating.  This inspection, which specifically focused on ORs subject to DRDL on-going improvement activities, found the following.

ONR confirmed the implementation of revised safety management arrangements and obtained evidence of significant improvements in dockside crane operations safety conditions and limits compliance.  ONR were broadly satisfied that its expectations were met in regard to the ORs inspected.

At the current time, ONR is not in a position where it can rate DRDL’s compliance with LC23 as ‘GREEN’, this is because of the following.

To date, the improvement programme has only been partially rolled out and a significant number of ORs and associated Identified Operating Instructions (IOIs) still require review.

The scope of the inspection was extremely limited and tightly focused around improvements to specific ORs, previously discussed with ONR.

Within the sample inspected, a number of further improvements were identified to fully meet ONR expectations for LC23.

In order to achieve a ‘GREEN’ rating, ONR requires further evidence of its expectations being met across a broad range of ORs across the licensed site.  ONR stated the intention to undertake an LC23 inspection, in approximately six months, in a location to be specified.  ONR stated that if DRDL continued to demonstrate the implementation of improvements, as had been done during this inspection, it anticipated a positive inspection outcome.

ONR will use the evidence obtained from the current inspection to inform its judgement as to whether DRDL has responded adequately to ONR concerns outlined in the November 2016 letter.

ONR will continue to engage with DRDL on this topic and revisit its enforcement strategy as new evidence comes to light.

Conclusion of Intervention

I judge that the licensee’s approach to the identification and implementation of ORs falls below the expected standard as outlined in the relevant TIG with further improvements being identified to fully met ONR expectations.  I recognise DRDL is currently implementing a programme of improvements and evidence of significant benefits arising from modifications to safety management arrangements were noted.  I anticipate, should improvements continue to be implemented, DRDL will be able to achieve sustained LC23 compliance in the future.