Office for Nuclear Regulation

Devonport - LC 27 and 28 compliance inspection

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 2019/20 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.

DRDL recently supplemented its licence condition compliance arrangements for Licence Condition 27, and is currently carrying out improvements to compliance arrangements for Licence Condition 28.

The intervention targeted safety mechanisms, devices and circuits (SMDCs) related to dockside crane operations on 15 dock which are safety significant plant.  The aim of the intervention was to confirm that dockside cranes are not operated, inspected, maintained or tested unless suitable and sufficient SMDCs are properly connected, controlled (Licence Condition 27) and in good working order (Licence Condition 28).

The inspection was undertaken by conducting interviews with licence condition owners, procedure authorisation groups, maintenance managers and procedure authorisation coordinators.  The configuration and control of the crane safety systems was inspected by examining the arrangements defining dockside crane safety systems and subsequent control through the procedure authorisation group, as implemented by the plant operations coordinator.  The plant maintenance schedule and associated maintenance records were sampled for a number of dockside crane safety systems.  The inspection was carried out by two site inspectors and the Head of Internal Nuclear Oversight from DRDL.

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 implemented the revised arrangements for LC 27 prior to the docking of HMS Triumph.  In my opinion the improvements have been successfully implemented and are enduring. 

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.  Four maintenance activities associated with nuclear safety significant plant were inspected. 

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.  I therefore rated compliance GREEN – no formal action.