Office for Nuclear Regulation

DRDL - LC27 and LC28 planned inspections

Executive summary

Purpose of Intervention

This intervention was carried out at the Devonport Royal Dockyard Limited (DRDL) licensed site and was undertaken as part of the 2017/18 intervention plan and propulsion sub-division strategy.

Interventions Carried Out by ONR

ONR carried out planned Licence Condition 27 (Safety mechanisms, devices and circuits) and 28 (Examination, inspection, maintenance and testing) compliance inspections in line with the ONR Technical Inspection Guides NS-INSP-GD-027 and NS-INSP-GD-028 respectively.  The inspection plan was sent to DRDL in advance of the inspection.

The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.

The scope of the intervention was 9 dock’s Plant Maintenance Schedule and the progress on two existing regulatory issues.  DRDL is currently carrying out improvements to its licence condition and authorisation condition compliance arrangements, and consequently the arrangements were not examined by this inspection.

The inspection was undertaken by conducting interviews and physically inspecting maintenance activities in 9 dock.  The inspection was targeted on safety significant plant.  It was carried out by three site inspectors and a mechanical engineering specialist.

Explanation of Judgement if Safety System Not Judged to be Adequate

A system/structure based inspection was not carried out.

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

DRDL has made progress in resolving the regulatory issue concerning deficiencies in LC 27 arrangements.  Revised arrangements have been developed and DRDL stated they will be implemented in time for the next docking in 15 dock, and will subsequently be implemented on 9 dock. 

DRDL has also made progress on a second issue concerning the approval of maintenance schedules. ONR will continue to monitor and engage with DRDL on this issue.

The inspection found that DRDL is continuing to make progress in developing its arrangements, which when fully implemented will meet regulatory expectations. 

The scope of the inspection included scrutiny of maintenance that had recently been carried out.  It found that examination, inspection, maintenance and testing (EIMT) activities appeared to be suitably controlled by a software package; maintenance instructions are available and records are completed and retained.  Two maintenance activities associated with nuclear safety significant assets were inspected.  It was noted that there were areas of local degradation around assets which were not recorded as defects in the corresponding records.  I judged this to be a shortfall against the requirements in LC 28.  I will raise a corresponding level 3 regulatory issue to seek improvement. 

Conclusion of Intervention

No shortfalls or issues were found which significantly affect nuclear safety or were judged to be of such regulatory concern as to require immediate action. 

The two extant issues relating to LC 27 and 28 will remain open and can be closed when adequate arrangements have been implemented.  An additional level 3 regulatory issue will be raised regarding the condition of systems, structures and components on 9 dock with a specific focus on the identification and tracking of defects.