Office for Nuclear Regulation

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Devonport Royal Dockyard - Licence Conditions LC15 Inspection, LC14 Routine Engagement and Low Level Refuelling Facility Safety Case Meeting

Executive summary

Purpose of Intervention

This intervention at the Devonport Royal Dockyard Limited (DRDL) Devonport licensed site was undertaken as part of the 2017/2018 ONR planned inspection plan for the site.

Interventions Carried Out by ONR

The inspection examined DRDL's arrangements made under Licence Condition (LC) 15 for Periodic Review. The LC was inspected using ONR's relevant Technical Inspection Guide.

Explanation of Judgement if Safety System Not Judged to be Adequate

ONR has two open regulatory issues on DRDL's LC15 arrangements relating to the comprehensive nature of DRDL reviews and the arrangements for interim reviews. This inspection considered whether evidence was available that DRDL is addressing these regulatory issues. During this inspection DRDL could not provide an agreed DRDL strategy for cycle 2 of their periodic review of safety (PRS), a document informing ONR the scope of the reviews and how the site has been broken down in such a way that would represent a comprehensive review of site facilities. I stated that until I have had this information I cannot make any judgements on DRDL's periodic review arrangements. Therefore, I rated DRDL's arrangements as below standard (Amber) in line with the judgements of ONR's previous inspection.

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

The LC15 compliance inspection found that:

DRDL do not have finalised documents providing the strategy or scope for their upcoming cycle of periodic reviews (scheduled to start in September 2017).

No evidence was provided that DRDL has addressed the concerns of ONR's previous inspection related to the comprehensive nature of their periodic review studies.

DRDL do not have formal arrangements for the provision of interim reviews.

DRDL is making progress in addressing the shortfalls raised during the first cycle of periodic reviews, with completion expected early 2019.

Overall, I rated DRDL's arrangements as below standard (Amber) in line with the judgements of ONR's previous inspection.

Conclusion of Intervention

Based upon the evidence examined during this inspection, I consider that DRDL's LC15 arrangements remain below standard (Amber). I stated that I had not seen any evidence that would address the two open regulatory issues on DRDL's LC15 arrangements. I have modify the regulatory issues to include ONR's expectation to receive DRDL's PRS cycle 2 strategy document, basis document, training material and their revised arrangements for interim reviews.