Office for Nuclear Regulation

DRDL - LC23 and LC24 Compliance Inspections

Executive summary

Purpose of Intervention

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

Interventions Carried Out by ONR

This inspection examined the adequacy of DRDL’s arrangements and subsequent implementation for Licence Condition (LC) 23 operating rules (ORs) and LC24 operating instructions.  It focussed on operations that may affect safety which were ongoing during the inspection in the Submarine Refit Complex (SRC) and 9 Dock.

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

From the evidence obtained from DRDL during this inspection, I am of the opinion that:

the Licensee is, for the operations sampled, controlling and carrying them out in compliance with the identified ORs; and

these operations are being carried out in accordance with written instructions.

A number of recently implemented improvements / good practices were observed during this inspection.

SRC “Node Zero” allows ORs which are only required when boats are present to be “switched off”.  This significantly reduces burden / workload associated with compliance with conditions and limits when no nuclear safety consequence can occur.  “Node zero” is seen as a key facilitator of current improvement / risk reduction activities such as pedestal removal.

Demonstration from those with responsibility for OR compliance of appropriate comprehension of safety case requirements, the method via which these requirements are to be fulfilled on site and the potential negative nuclear safety consequences which may arise from OR non-compliance.

Commitment from individuals charged with OR compliance to investigate, capture and ultimately implement improvements.  Examples included an observed safety stand down which communicated the conditions and limits associated with the work to be completed in a highly effective and efficient manner.  The use of different operating instruction formats, aimed at supporting specific job demands, was also noted as good practice.

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

A small number of specific areas of improvement were identified during this inspection. The most notable of which was whether personnel should be required to obtain confirmation from the relevant technical authority that OR compliance will not be challenged, prior to the adjustment of a Structure, System or Component (SSC) claimed in the safety case.  This was current practice but not a mandatory requirement.  Additionally some minor shortfalls were observed against the regulatory expectation that records demonstrating compliance with ORs are made and stored, however no shortfall in actual compliance was observed.  A regulatory issue will be raised to monitor the implementation of associated improvements.

Conclusion of Intervention

No matters were identified as requiring immediate regulatory attention during the conduct of this LC 23 and 24 compliance inspection

I was broadly satisfied that the operations sampled were being controlled and carried out in compliance with the conditions and limits that DRDL has identified as being necessary in the interest of safety.  I was also broadly satisfied that these operations were being completed in accordance with written instructions which included: the instructions necessary in the interest of safety and those required to ensure ORs are implemented.  As such I rated the inspection as a Green for both LC23 and LC24.  A Level 4 regulatory issue will be raised to monitor DRDL’s resolution of the areas for improvement highlighted by the inspection.

Acknowledging the small sample of ORs inspected, the Green rating awarded should not be taken as an indication that all previously identified concerns related to these LCs have now been resolved.  Whilst evidence of continuing improvement was observed during this inspection, a number of regulatory issues remain open against which further improvement is sought by ONR.  I welcome DRDL’s commitment to continue to support the NSIP (Nuclear Safety Improvement Programme) and NOIP (Nuclear Operations Improvement Programme), which aim to deliver these improvements and integrate them into normal business practices.