Office for Nuclear Regulation

LC 35 Compliance inspection

Executive summary

Purpose of Intervention

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

Interventions Carried Out by ONR

I conducted a Licence Condition 35 (Decommissioning) compliance inspection. The inspection focused on the implementation of the licensee’s post operational clean out (POCO) arrangements and the licensees decommissioning strategy across the site. The Nuclear Liabilities Regulation Specialist review of the licensee decommissioning strategy aligns with the obligation placed on the Office for Nuclear Regulation to conduct a Quinquennial Review of the licensees decommissioning strategy “to ensure that operators' decommissioning strategies remain soundly based as circumstances change” (White Paper Cm2919).

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

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

The inspection of the DRDL Decommissioning and POCO Strategy identified a number of minor observations. Of note, was that the DRDL Decommissioning and POCO strategy is currently in draft. Feedback was provided to the author of the document.

The DRDL Internal Nuclear Assurance group had previously reviewed the adequacy of all licence condition arrangements. The INA review identified a number of shortfalls within the licensee’s compliance arrangements for Licence Condition 35 (Decommissioning). The Internal Nuclear Assurance group findings aligned with the evidence viewed by ONR during the inspection.

Based upon the evidence sampled, I judge that the regulatory expectation to consider decommissioning during the initial design phase of a project was not adequately captured within DRDL’s arrangements.

As no decommissioning activities are being undertaken, and no detailed designs are being produced, I am satisfied that there is no imminent impact to nuclear safety due to these shortfalls. To monitor the licensees’ progress against these shortfalls a single Level 4 Regulatory Issue is raised titled ‘LC 35 Decommissioning Shortfalls’.

Conclusion of Intervention

On the basis of the evidence sampled, in line with ONR Inspection Rating Guidance, it is my judgement that the licensee has identified the relevant shortfalls and required improvements and has a process to monitor progress. Therefore, at this time, I considered that the licensee has adequately demonstrated compliance with Licence Condition LC35 (Decommissioning) and that an inspection rating of Green (no formal action required) is merited.