Office for Nuclear Regulation

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Devonport - Readiness inspection

Executive summary

Purpose of Intervention

This intervention at the Devonport Royal Dockyard Limited (DRDL) licensed site, was undertaken to conduct a readiness review prior to the start of defuel activities.  The focus was on the confirmation of the actions taken following an ONR enforcement letter, in response to an incident related to the nuclear transfer route, which had occurred in September 2018. The intervention also sought to review the adequacy of the plant manager’s controls on the start of defueling operations delivered through the hold point control system.

Interventions Carried Out by ONR

The enforcement letter, ONR-EL-19-002, identified a number of requirements that DRDL should address following the 2018 incident. The inspection sampled the updated documents and arrangements through which DRDL sought to demonstrate that they had implemented safety improvements to the control and conduct of nuclear transfer route and crane activities.

This inspection also examined the implementation of DRDL’s arrangements for hold point control of the start of used fuel removal operations.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable

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

In response to the crane rail infill event and the ONR enforcement letter, DRDL has delivered a range of improvements:

These have delivered noticeable safety improvements in the planning, control and conduct of the nuclear transfer route and crane activities.

We judged that DRDL had sufficiently addressed the requirements of enforcement letter (ONR-EL-19-002) to support the start of used fuel removal operations.  We note that there are a limited number of actions outstanding to fully close out the enforcement letter.

DRDL had a comprehensive range of deliverables prior the start of used fuel removal and we judged that the hold point control arrangements for the start of used fuel removal were adequate.  However, we considered better clarification of the maintenance status for the facilities should be sought to address an action from an extant regulatory issue. This will be followed up during routine regulatory engagements.

No matters were identified as requiring immediate regulatory attention during the conduct of this readiness review.

Conclusion of Intervention

No matters were identified as requiring immediate regulatory attention during the conduct of this readiness review.

I was satisfied that adequate safety improvements had been implemented following the crane rail infill event and the subsequent ONR enforcement letter to support used fuel removal.  I was also broadly satisfied that DRDL had implemented adequate hold point control arrangements for the start of used fuel removal.