Office for Nuclear Regulation

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Rosyth - LC13, LC14 and LC15 planned compliance inspections

Executive summary

Purpose of Intervention

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

Interventions Carried Out by ONR

I conducted Licence Condition (LC) compliance inspections for the following LCs:

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

Not applicable.

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

I carried out my inspection on the licensee’s documentation and processes covering activities at the Active Waste Accumulation Facility (AWAF) and the Submarine Dismantling Project (SDP) at 2 Dock.

From the evidence provided by RRDL during the LC 13 inspection, I am of the opinion that the Licensee has adequately implemented the arrangements described in its Nuclear Safety Committee (NSC) Terms of Reference document. In my opinion there is a lack of clarity in some of RRDL’s supporting procedures on the role of the NSC and the level of advice that should be provided to the licensee’s management. Given the sample of evidence considered, I have not identified any significant concerns with the current NSC outputs. However, there would now be benefit in clarifying the role of the NSC, to ensure that the committee is providing an appropriate level of advice to support the forthcoming SDP Stage 2 activities.

Given the type of facilities and the associated level of risk, I consider that RRDL has adequate LC 14 arrangements in place for the production of its safety cases and for managing safety justifications to support modifications.

In my opinion, RRDL has established the intent to carry out interim and periodic reviews to comply with LC 15, but has not yet developed or implemented adequate detailed procedures for these. New safety cases were completed in 2017 for both the AWAF (in response to the last periodic review in 2015) and for commencement of SDP Stage 1 activities. I therefore have no immediate nuclear safety concerns with the status of RRDL’s periodic review process. However, my expectation is that RRDL should prepare detailed procedures for periodic review and that a programme of reviews (both interim and full ten year reviews) is established.

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

Conclusion of Intervention

No matters were identified as requiring immediate regulatory attention during the conduct of the LC 13, 14 & 15 compliance inspections.

For LC 13, I concluded that the licensee has adequately implemented its arrangements for the NSC. I consider that an inspection rating of Green (no formal action required) is merited, but that a Level 4 Regulatory Issue should be raised to secure improved clarity on the role of the NSC.

I consider that RRDL has adequate LC 14 arrangements in place for the production of its safety cases and for managing safety justifications to support modifications. The arrangements are proportionate given the type of activities carried out and the relatively low levels of risk.

RRDL has established the intent to carry out LC 15 periodic reviews, but has not yet developed or implemented adequate detailed procedures for these. My expectation is that RRDL should prepare detailed procedures for periodic review and that a programme of reviews (both interim and full ten year reviews) is established. I propose to raise a Level 3 Regulatory Issue to secure the necessary improvements. However, I note that new safety cases were completed in 2017 for both the AWAF (in response to the last PRS in 2015) and for commencement of SDP Stage 1 activities in 2 Dock. I therefore have no immediate nuclear safety concerns with the status of RRDL’s periodic review process.