Office for Nuclear Regulation

LC14 Inspection at Devonport Royal Dockyard

Executive summary

Purpose of intervention

This intervention at the Devonport Royal Dockyard Limited Licensed Site was undertaken as part of the 2015/16 intervention plan and Propulsion sub-programme strategy.

Interventions Carried Out by ONR

The main purpose of this visit was: to carry out an LC 14 (Safety Documentation) compliance inspection.

Explanation of Judgement if Safety System Not Judged to be Adequate

A system based inspection was not carried out.

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

DRDL has made and implemented arrangements for the production and assessment of safety cases.  DRDL has improved the understanding and visibility of the safety cases by improving training for facility personnel.   Consultation with the end-user has been significantly improved during the production of recent safety cases and this has led to better understanding of the operating rules and their implementation.

DRDL’s nuclear safety committee identified a number of deficiencies when it reviewed DRDLs latest safety case, which had to be addressed before the committee considered and provided advice on the case.  ONR has also identified shortfalls in safety cases which have been submitted for assessment and has written to DRDL outlining the deficiencies.  DRDLs internal checking and verification process did not identify and remedy these deficiencies before reaching the NSC and submission to ONR.  The arrangements do not achieve the planned results and were therefore judged to be below standard.

This inspection identified a number of shortfalls in the LC 14 arrangements.

In response to the NSC’s views and ONR’s letters DRDL recognises that improvements are needed and is about to initiate an independent external review of their approach to modern standards safety cases.  I consider this to be a satisfactory response.

Conclusion of Intervention

Taking into account the inspection findings above I judged compliance with LC 14 is currently below standard.

I believe the planned review of the safety case arrangements and subsequent improvement actions, if carried out appropriately, will substantially improve the safety case arrangements and remedy the majority shortfalls identified in this inspection.  I have therefore not raised any additional improvement actions but I expect the review to consider the shortfalls identified during this inspection.

I have raised an issue on the ONR database and will to monitor DRDL’s response to making further improvements in the safety case arrangements.