This intervention, conducted at the Licensee’s Devonport Royal Dockyard Limited (DRDL) Devonport licensed site and was undertaken as part of the 2017/18 intervention plan and propulsion sub-division strategy.
I conducted a Licence Condition (LC) 14 “Safety Documentation” compliance inspection, focused on the implementation of the Licensee’s arrangements for the licence condition, specifically their arrangements for managing safety documentation, including modifications to third-party safety cases and ensuring that requirements of their safety cases are implemented.
The intervention was performed in line with ONR’s guidance requirements (as described in our technical inspection guides) in the areas inspected.
From the evidence presented by DRDL during this inspection, I am of the opinion that the Licensee is effectively managing and maintaining their safety cases. It was noted that the Licensee is currently developing formal processes to support this activity. I consider this key for compliance with LC14 and as such I will monitor the development and implementation of these processes.
DRDL’s arrangements for responding to modifications to third-party cases (such as those produced for submarine reactor plant on behalf of the MoD) are not currently captured by a formal process. DRDL are informed of modifications to third-party safety cases and consider that they currently respond appropriately, however, they acknowledge the lack of a formal process and agreed to address this. I will monitor the development and implementation of this process.
DRDL were able to demonstrate to my satisfaction how the requirements of the safety case are captured and implemented into working level documentation, training, etc.
No matters were identified as requiring immediate regulatory attention during the conduct of the compliance inspection.
I will raise a regulatory issue so that I can monitor DRDL’s development and implementation of formalised processes for the management and implementation of their safety cases, and for responding to modifications to third-party cases.
No matters were identified as requiring immediate regulatory attention during the conduct of the LC 14 compliance inspection.
I was satisfied that DRDL are appropriately managing their safety documentation, including modifications to third party safety cases, and ensuring that all requirements of their safety cases are captured in working level processes. As such I rated the inspection as a Green. A Level 4 regulatory issue has been raised to monitor DRDL’s development and implementation of formal processes to support the LC 14 arrangements.
There are known issues with some aspects of the safety case production process; these gaps are already captured by regulatory issues. Therefore, I consider improvement should still continue to be sought with regard to DRDL’s wider LC14 arrangements.