Office for Nuclear Regulation

Compliance inspection of LC28

Executive summary

Purpose of Intervention

This intervention, conducted at the licensee’s (Devonport Royal Dockyard Limited - DRDL) Devonport site, was undertaken as part of the 2020/21 intervention plan and propulsion sub-division strategy.

Interventions Carried Out by ONR

I conducted a Licence Condition (LC) 28 (examination, inspection, maintenance, and testing) compliance Inspection with the inspection focused upon the following purposes:

The intervention was also used to undertake an assessment of the adequacy of DRDL’s arrangements for compliance with COVID-19 social distancing and other health protection measures, and the implementation of these measures on site. 

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

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

It is my opinion that with respect to the areas sampled, DRDL has adequate arrangements in relation to LC28.  In my opinion DRDL have recognised historical shortfalls in their implementation of maintenance delivery, and have now piloted the establishment of closer control over the delivery of maintenance tasks within a number of facilities.  Whilst the licensee has yet to embed that proportionate and proactive approach to maintenance delivery across the site, initial sampled evidence indicates that this approach is adequate. 

All personnel interviewed through the intervention were clear on their responsibilities for safety and had sufficient means and ability to discharge these responsibilities.  In particular, those charged with control of lifting equipment were notably well informed and demonstrably experienced in the management of statutory maintenance.

DRDL’s arrangements were judged to be in compliance with current Government guidance in relation to working safely during COVID-19 in factories, plants and warehouses. The arrangements were judged to be effectively implemented.

Conclusion of Intervention

Overall, I judged that the licensee’s arrangements for LC28 are adequate and have been appropriately implemented.  On the basis of evidence obtained during the intervention I have given an inspection rating of green for LC28 (examination, inspection, maintenance and testing)

In relation to COVID19 social distancing and other health protection measures, I judged that the licensee’s arrangements are adequate, in full compliance with government advice and guidance and have been effectively implemented.