Office for Nuclear Regulation

Licence Condition 22 (Modification or experiment on existing plant) compliance inspection

Executive summary

Purpose of Intervention

The purpose of the intervention was to inspect and assess the adequacy of the Rosyth Royal Dockyard Ltd (RRDL) revised arrangements for the management and control of modifications including construction, modification, installation and commissioning of new and existing plant, in response to four findings raised following an LC19-22 inspection undertaken on 20th November 2019 (ONR-OFD-IR-19-114, CM 2019/345903).

This was a planned inspection, in line with the ONR Integrated Intervention Strategy (IIS) plan for 2020/21 of the RRDL licensee on the Rosyth nuclear licensed site.

Due to COVID 19 restrictions, the inspection was performed remotely via teleconference and shared documentation.

Interventions Carried Out by ONR

The focus of the inspection was to consider the adequacy of RRDL’s revised arrangements under Licence Condition (LC) 22 (Modification or experiment on existing plant). RRDL have revised their arrangements in response to four ONR findings, listed below, which were raised following the previous LC19-22 inspection (ONR-OFD-IR-19-114, CM 2019/345903):

The inspection was conducted in line with the inspection plan provided to RRDL ahead of the intervention (CM 2020/222770). The inspection was informed by the expectations outlined within the relevant ONR Technical Inspection Guide (TIG) for LC 22, ONR-NS-INSP-GD-022, Revision 5.

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.

At the time of the inspection, the revisions which are being made to RRDL’s arrangements under LC 22 were presented to ONR as draft proposals.  I considered evidence of RRDL’s response to each of ONR’s earlier findings to be positive, with the following observations being noted:

Whilst I regard the licensee’s response to ONR’s previous four findings as positive, at the time of this inspection ONR were presented with draft documentation; none of the revisions to the arrangements under LC 22 has completed due process and been formally issued.  This factor is accounted for in my conclusion for the intervention.

Conclusion of Intervention

On the basis of the evidence sampled at the time of the inspection, in my opinion the licensee is progressing with improvements to their arrangements which, when completed and formally issued, should adequately address the four findings of the previous LC22 planned inspection.

Whilst my observations from the inspection are positive, because the documentation sampled at the time of the inspection has yet to be formally issued by RRDL, I judged that it would not be appropriate to apply a formal inspection rating to this intervention.

Therefore, I consider that an inspection rating of ‘not rated’ is appropriate.

The ONR site inspector will track RRDL’s progress towards issuing the revised arrangements as part of his normal regulatory business; I do not consider it necessary to raise any further recommendations.