Office for Nuclear Regulation

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LC 27 and 28 Compliance Inspection

Executive summary

Purpose of Intervention

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

Interventions Carried Out by ONR

ONR carried out planned Licence Condition 27 (Safety mechanisms, devices and circuits) and 28 (Examination, inspection, maintenance and testing) compliance inspections in line with the ONR Technical Inspection Guides NS-INSP-GD-027 and NS-INSP-GD-028 respectively.  The inspection plan was sent to DRDL in advance of the inspection.

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

The scope of the intervention was 15 dock’s Plant Maintenance Schedule and the progress on two existing regulatory issues.  DRDL is currently carrying out improvements to their licence condition and authorisation condition compliance arrangements, and consequently the arrangements were not examined by this inspection.

Explanation of Judgement if Safety System Not Judged to be Adequate

A system/structure based inspection was not carried out.

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

The inspection was undertaken by conducting interviews and physically inspecting maintenance activities in 15 dock.  The inspection was targeted on safety significant plant.  It was carried out by the site inspector and a mechanical engineering specialist.

DRDL has made significant progress in resolving the regulatory issue concerning deficiencies in LC 27 arrangements.  Revised arrangements have been developed and DRDL stated they will be implemented in time for the next docking.  There has been limited progress on a second issue concerning the approval of maintenance schedules, and ONR will engage with DRDL to identify a way forward.

Two safety significant maintenance activities were inspected.  The maintenance tasks were identified in the plant maintenance schedule and carried out in accordance with procedures and instructions.  Control and supervision of the work was satisfactory and adequate records were maintained.  No issues were found.

Conclusion of Intervention

The inspection of two safety significant maintenance tasks found maintenance was being carried out in accordance with LC 28 requirements.  No issues were identified.

The two extant issues relating to LC 27 and 28 will remain open and can be closed when adequate arrangements have been implemented.  Further engagement will be needed regarding the approval of maintenance schedules.