Executive summary
Date(s) of inspection:
July 2025
Aim of inspection
To judge the adequacy of RRDL's implementation of its safety documentation production arrangements made under Licence Conditions (LC) 14 and 22.
Subject(s) of inspection
- LC14 - Safety documentation - Rating: Green
- LC22 - Modification or experiment on existing plant - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
The 2 Dock facility on the Rosyth Royal Dockyard nuclear licensed site is currently removing low level waste (LLW) from decommissioned submarines whilst preparing for readiness to commence removal of intermediate level waste (ILW). To facilitate ILW removal, Rosyth Royal Dockyard Limited (RRDL) is designing a new ILW handling facility as well as producing a supporting safety case to justify the safety of the associated ILW activities. This inspection judged the adequacy of RRDL's arrangements and their implementation for Licence Conditions (LC) 14 and 22, for both current activities as well as readiness for more hazardous future activities. Its purpose was gain assurance of RRDL's ability to adequately implement its arrangements for safety case production and governance and inform the future regulatory decision on whether to grant permission for RRDL to commence ILW removal. The inspection also followed up on RRDL's progress against previously identified regulatory shortfalls in these arrangements.
The inspection was undertaken and rated against published guidance on regulatory expectations, as described in ONR's technical inspection guides NS-INSP-GD-014 and 022 and ONR-INSP-GD-064. Based on the evidence sampled at the time of the intervention against RRDL's arrangements and documentation, and regulatory guidance, ONR judged that RRDL demonstrated adequate compliance with LCs 14 and 22.
Conclusion
Based on the findings of the intervention, ONR considers that RRDL has adequately implemented its arrangements for compliance with LC 14 and 22, specifically:
- for the production and assessment of safety cases consisting of documentation to justify safety during the design, construction, manufacture, commissioning, operation and decommissioning phases of an installation (LC 14);
- provide for the classification of modifications according to their safety significance, adequate documentation to justify the safety of a proposed modification and where appropriate for the submission of the documentation to ONR (LC 22).
It is therefore judged that an inspection rating of Green is merited, in accordance with ONR Guide ONR-INSP-GD-064, where relevant good practice was met when compared with appropriate benchmarks; legal duties were complied with; and, no safety shortfalls were identified in the delivery of safety functions. We did identify a potential compliance gap with RRDL's human factors arrangements and agreed that the required improvements will be tracked via a Level 4 regulatory issue. As part of the inspection we also sampled evidence of compliance with regulatory issue RI-12015 associated with RRDL's holistic review and update of its broader LC compliance arrangements and judged that RRDL provided satisfactory evidence to close out all three actions.