Executive summary
Date(s) of inspection:
July 2025
Aim of inspection
Rosyth Royal Dockyard (RRDL) is undertaking the waste removal and dismantling of 1st generation pressurised water reactor (PWR1) laid up submarines (LUSM) under the Submarine Dismantling Project (SDP). This is being undertaken in the following stages:
-
Stage 1: Removal of Low Level Waste (LLW) reactor system pipework and pressure vessels (other than Reactor Pressure Vessel (RPV)/ Primary Shield Tank (PST)).
-
Stage 2: Design and build of Waste Processing Facility (WPF). Removal of the RPV and PST and transfer to the WPF. RPV and PST separation and loading of the RPV into the RPV Transport Container (RPVTC). Preparation of RPVTC for offsite disposal. Disposal of the PST and other waste arisings.
-
Stages 3/4: Whole boat security and radiological de-classification and final dismantling of the LUSM noting these will be undertaken in parallel.
Stage 1 activities have largely been completed for several submarines and RRDL has now commenced both Stage 2 construction works and Stage 4 dismantling works for the LUSM currently in dock. The aim of this inspection is to judge the adequacy of RRDL, other contractors and dutyholder's compliance with the Construction (Design and Management) Regulations 2015 (CDM) on the Submarine Dismantling Project (SDP) Stage 2 and 4 construction and dismantling activities respectively. ONR will seek to gain assurance of the management of conventional health and safety hazards present on the construction sites with a specific focus on the:
- Appointed CDM Roles and how they are discharged.
- Planning, organising and control of work.
- Major hazards on site and how they are controlled.
Subject(s) of inspection
- CDM 15 (Client / PD / PC duties) - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
The Office for Nuclear Regulation (ONR) undertook a planned inspection of work being carried out to dismantle a 1st generation pressurised water reactor laid up submarine at Rosyth Royal Dockyard (RRDL) as part of their Submarine Dismantling Project (SDP).
The aim of the inspection was to judge the adequacy of RRDL, other contractors and dutyholders' compliance with the Construction (Design and Management) Regulations 2015 (CDM)
ONR sought to gain assurance that conventional health and safety hazards present at this site were being suitably managed by each dutyholder. This included gathering information regarding:
-
Appointment of CDM Roles and how these roles are being discharged.
-
The planning, organising and control of work being undertaken.
-
Major hazards on site and how they are being controlled.
The inspection consisted of:
-
Desktop discussions to allow RRDL to demonstrate compliance with CDM. Safety documentation including designers risk assessments and the PC’s risk assessment and method statements (RAMS) for certain tasks and activities may also be sampled as necessary.
-
A site walkdown to observe how hazards on site were currently being controlled by the PC.
-
Attending a 'plan of the day'/'plan of tomorrow' meeting to observe the dutyholders arrangements for effective cooperation in developing, promoting and checking the effectiveness of measures to ensure the health, safety and welfare of workers;
Findings
Information shared during the discussions gave ONR confidence in the CDM arrangements at this site. CDM roles had been appointed and were being discharged in compliance with CDM. Monitoring arrangements were also adequate.
On the whole, good health and safety management was evident in the work activities observed with a few observations made.
Recommendations
ONR have formally requested that RRDL respond to them detailing how they intend to address the two points raised below:
-
RRDL should satisfy themselves that RAMS produced by the PC are appropriate for the work being undertaken.
-
RRDL should review the interface between Babcock and KDCV to ensure clarity over lifting operations specifically regarding supervision and control.
Conclusion
On the basis of the evidence sampled for discharging of CDM roles, and how work was being planned, organised, controlled and carried out, I judge that the relevant good practice was generally met when compared with appropriate benchmarks and I have rated the inspection as green.