Office for Nuclear Regulation

Compliance Inspection of LC 14 – Safety Documentation

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

I conducted a Licence Condition (LC) 14 “Safety Documentation” compliance inspection, focused on the implementation of the Licensee’s arrangements for the licence condition, specifically their arrangements for the production of safety cases.

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 presented by DRDL during this LC14 inspection, I am of the opinion that the Licensee is effectively implementing its existing arrangements for the production of safety cases. This judgement is based on an inspection of work done to date to develop a new safety case for the Nuclear Utilities Building and Active Water Treatment Plant.

The new safety case has been developed as a parallel exercise to DRDL’s LC15 cycle 2 periodic review of safety. In my opinion, the Licensee has not clearly demonstrated the link between the LC15 expectations for review of the extant case, and the development of the new case. This issue is being dealt with separately as part of ONR’s assessment of DRDL’s LC15 periodic review submission.

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

Conclusion of Intervention

No matters were identified as requiring immediate regulatory attention during the conduct of the LC 14 compliance inspection.

I was satisfied that DRDL are implementing their current arrangements for developing safety cases. As such I rated the inspection as Green.

There are known issues with some aspects of the existing safety case production procedures, specifically in relation to categorisation of safety functions and classification of structures, systems and components. These gaps are already captured by a regulatory issue and progress to improve procedures is being monitored by ONR.