Office for Nuclear Regulation

Compliance inspection of LC 15 – Periodic Review

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 2019/20 intervention plan and propulsion sub-division strategy.

Interventions Carried Out by ONR

I conducted a Licence Condition (LC) 15 “Periodic Review” compliance inspection focused on the Licensee’s arrangements, which will support Cycle 2 of its periodic review of safety.

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 during the inspection, the Licensee does not yet have in place complete and consistent procedures and guidance documents to support implementation of its cycle 2 of periodic review (PRS2). On this basis, I have not seen the evidence to demonstrate that the Licensee has adequate arrangements in place for LC 15.

However, I consider that significant progress has now been made to address previous shortfalls as part of the development of the process to support PRS2. Across the suite of documents which currently exist, there is evidence that key elements of relevant good practice have been incorporated. This is an improving position, but I consider that further work is still required to finalise the arrangements.

In my opinion, the Licensee needs to carry out a review of the suite of documents to ensure consistency and consolidate documents where appropriate, including between the process and procedures and the PRS2 scope and basis. The Licensee also needs to complete and issue its guidance document to support the process and procedures. This needs to ensure that the guidance reflects the Licensee’s own learning and previous ONR comments and feedback. I am satisfied that the Licensee recognised and understood the shortfalls identified in the inspection, and intends to carry out the necessary work to address the remaining gaps.

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

Conclusion of Intervention

The Licensee does not yet have in place complete and consistent documents which describe its LC 15 arrangements. On this basis an Amber inspection rating is appropriate (seek improvement).

I have seen evidence that this is an improving position and that key elements of relevant good practice are in place. I have confidence that, once proposed further work has been completed, the Licensee will be in a better position to demonstrate LC compliance.

No new matters were identified as requiring immediate regulatory attention during the inspection. Areas of concern are already covered by extant regulatory issues 4722 and 4723 which remain open as a result of this inspection.

I am satisfied that the Licensee understands the shortfalls and what needs to be done to meet relevant good practice. The regulatory issues, and the wider implementation of arrangements for PRS2, will continue to be managed through a quarterly regulatory interface forum specifically covering the Licensee’s periodic review activities.