This intervention at the Devonport Royal Dockyard (DRDL) licensed site was undertaken in order to conduct licence condition compliance inspections as scheduled in the DRDL integrated intervention strategy.
ONR carried out the licence compliance inspections below:
The inspections assessed the adequacy of the arrangements and their implementation.
Licence Conditions (LCs) 10, 12, 18, 27 & 28 compliance inspections were undertaken, and facility familiarisation walk downs in the nuclear utilities building (NUB) and radio chemistry laboratory (RCL). A series of meetings were undertaken with DRDL to understand planned modifications and future projects and interventions to introduce conduct of operations. During this intervention we also followed up the reported missed maintenance events INF 2017/569.
A system/structure based inspection was not carried out.
An inspection was carried out to assess compliance with LC 27 (safety mechanisms, devices and circuits) (SMDCs). I found that DRDL is still carrying out corrective actions from a previous ONR inspection to identify safety mechanisms, devices and circuits and implement arrangements to ensure they are in place. I judged this to be a shortfall against the requirements in LC 27 and the guidance to inspectors in NS-INSP-GD-027. I will write to DRDL seeking improvement to this corrective action process and reinforcing our expectation that the shortfall must be addressed. I have also raised a level 3 regulatory issue. I judged that this deficiency can be tolerated in the short term because DRDL has LC 23 and 24 arrangements in place to ensure operating rules and identified operating instructions are adhered to, and in many cases these ensure safety related equipment is available. However, DRDL's proposed corrective action needs to confirm that the totality of SMDCs are covered. A licence condition owner has been appointed for LC 27 and future interventions can determine if this is contributing to continual improvement of the arrangements.
An inspection was carried out to assess compliance with LC 28 (examination, inspection, maintenance and testing). The scope of the inspection covered management arrangements, but its scope did not include detailed scrutiny of a maintenance task being carried out because ONR is currently carrying out an investigation on this topic. It found that examination, inspection, maintenance and testing (EIMT) activities appeared to be suitably controlled by a software package, maintenance instructions are available, and records are completed correctly and retained. The inspection found that DAPs and SQEPs were appointed to supervise the maintenance work. Discussion with maintainers showed they had an understanding of safety related equipment. Shortfalls were identified in the documentation describing the plant maintenance schedule (PMS). The documentation does not clearly describe the extent of the maintenance schedule for each facility and many individual PMSs for plant items and systems were not approved for use or formally issued to users. I judged this to be a shortfall against the requirements in LC 28. I will write to DRDL seeking improvement and have raised a corresponding level 3 regulatory issue.
A licence condition owner has been appointed for LC 28 and he has commissioned a review of compliance and developed a compliance project management plan. The findings of his review are consistent with ONR's and the planned actions will significantly improve the arrangements if implemented. ONR will monitor delivery of the improvement plan in this area as part of routine regulatory business.
An inspection was carried out to assess compliance with LC 18 (radiological protection). ONR judged the arrangements and doses to be adequate and rated this inspection green.
An inspection was carried out to assess compliance with LC 10 (training) and LC 12 (duly authorised and other suitably qualified and experienced persons). The inspection found that DRDL are continuing to make progress in developing arrangements, which when fully implemented, will meet regulatory expectations in technical inspection guidance. A number of shortfalls against regulatory expectations were identified; notably a structured approach to on the job training and the formal requirement to assess role-specific competence of all individuals duly authorised under LC 12 (e.g. DAPs and ASQEPs). Evidence of local good practices were found, which should be integrated into the licensee's formal arrangements. DRDL provided assurance that their extant Nuclear Safety Improvement Programme (NISP) will resolve these shortfalls however timescales and resource remain a challenge. ONR will continue to monitor progress via an extant regulatory issue.
DRDL confirmed that the contract has been placed for the removal of the pedestal in the submarine refit complex (SRC) and project implementation has started. Discussions were held regarding the modification controlling the project and I judged DRDL has reduced the risk by opting to use a suitably sized mobile crane. Therefore ONR will accept the Category B modification for information only.
No shortfalls or issues were found which significantly affect nuclear safety or were judged to be of such regulatory concern as to require immediate action. Two regulatory issues were raised to resolve shortfalls in compliance with LC 27 and 28. An extant regulatory issue remains open to resolve the shortfalls in compliance with LC 10 and 12.