Office for Nuclear Regulation

LC7 compliance inspection

Executive summary

Purpose of Intervention

This intervention at the Rosyth Royal Dockyard Limited (RRDL) 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) 07 (“Incidents on the site”) compliance inspection. I focused on the implementation of the licensee’s arrangements. This involved examination of relevant licensee documentation and incident management system, targeted discussions with relevant members of the licensee’s staff and inspection of the Active Waste Accumulation Facility (AWAF).

I assessed compliance against:

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable.

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

There were a number of areas of industry good practice observed at the site, including:

The following shortfalls identified during the compliance inspection and will be addressed through the raising of a regulatory issue.

The following was recommended as an area for improvement:

I undertook a physical inspection at the AWAF in support of the compliance inspection. I reviewed the implementation status of a number of corrective actions and checked staff members’ understanding of the LC7 reporting arrangements, and their understanding of how learning is shared on site.   

Based on the sampling that I undertook as part of the inspection, I have confidence that RRDL will continue to deliver the required enhancements to the LC7 compliance arrangements in a timely manner. This confidence is built on the self-identification that RRDL has already demonstrated, and the delivery to date of improvements to the reporting arrangements.

Conclusion of Intervention

Based on my inspection of the licensee’s arrangements for compliance with LC 07, I have identified areas of compliance where shortfalls still exist against relevant good practice. Whilst there are elements of good practice, the arrangements do not demonstrate compliance across all of the requirements of LC 07. Therefore I judge that an AMBER rating is merited.

Whilst a rating of AMBER would typically require a level 3 regulatory issue to be raised, I consider this to be disproportionate as the licensee has self-identified many of the inspection findings and continues to work to correct these. I therefore propose a level 4 regulatory issue to allow the work to be monitored through routine regulatory business.