Office for Nuclear Regulation

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LC15 inspection of the Nuclear Utilities Building PRS

Executive summary

Purpose of Intervention

This intervention, conducted at the Licensee’s Devonport Royal Dockyard Limited (DRDL) Devonport licensed site and was undertaken as part of the 2018/19 intervention plan and propulsion sub-division strategy.

Interventions Carried Out by ONR

I conducted a Licence Condition (LC) 15 “Periodic Review” compliance inspection, focused on the development and implementation of revised arrangements for the licence condition, specifically in relation to the periodic review of the Nuclear Utilities Building (NUB).

The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.

Explanation of Judgement if Safety System Not Judged to be Adequate

DRDL is currently undertaking a Periodic Review of Safety (PRS) of the Nuclear Utilities Building (NUB); this is due to be submitted to ONR in Summer 2018. The current draft documents do not meet ONR’s expectations, however I am satisfied that DRDL understands the shortfalls and has committed to addressing them before the final submission of its periodic review.

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

From the evidence presented by DRDL during this inspection, I am of the opinion that the Licensee has not adequately addressed all previous ONR inspection and assessment findings in the revised arrangements that are being followed for the periodic review of the NUB. This periodic review, which is the first of PRS cycle 2, is being carried out as a pilot exercise prior to finalisation and roll-out of revised arrangements for the periodic reviews of the remaining facilities.

No matters were identified as requiring immediate regulatory attention during the conduct of the compliance inspection.

There are extant Regulatory Issues from previous licence condition inspections which are relevant to the findings of this inspection. These will remain open until DRDL have finalised their revised LC15 arrangements (informed by learning from the NUB periodic review) and these have been subject to appropriate review by ONR. For this reason, I am satisfied that there is no reason to raise any further Regulatory Issues at this point in time.

Conclusion of Intervention

No matters were identified as requiring immediate regulatory attention during the conduct of the LC15 compliance inspection.

From the evidence presented during the inspection, I am of the opinion that the Licensee has not yet implemented satisfactory arrangements for compliance with LC15. The expectation is that DRDL will address ONR’s concerns in the NUB PRS and that the learning will then inform revised LC15 arrangements for wider roll-out across PRS cycle 2, including the  requirement to compare against ’modern standards’. As such I rated the inspection as Amber (seek improvement).

There are extant Regulatory Issues (4722 and 4723) relating to LC15 arrangements.  DRDL did not provide sufficient evidence in the inspection to allow closure of these Issues. Closure of these Issues cannot be progressed until DRDL have finalised their LC15 arrangements and these have been considered by ONR.

The wider PRS programme, and progress with closure of the extant Regulatory Issues, will be the subject of ongoing dialogue in appropriate Regulatory Interface Fora.