- Site: Rosyth
- IR number: 19-114
- Date: November 2019
- LC numbers: 22
Executive summary
Purpose of Intervention
This was a planned inspection, in line with the ONR Integrated Intervention Strategy (IIS) plan for 2019/20 of the Rosyth Royal Dockyard Ltd (RRDL) licensee on the Rosyth nuclear licensed site.
Interventions Carried Out by ONR
The focus of the inspection was both to consider licensee’s arrangements, made under Licence Condition (LC) 22 (Modification or experiment on existing plant), and the implementation of these arrangements on the Rosyth licensed site. The inspection was conducted in line with the inspection scope provided to RRDL ahead of the intervention (CM9: 2019/300626). The inspection was informed by the expectations outlined with the relevant ONR Technical Inspection Guides (TIG) for LC 22, ONR-NS-INSP-GD-022, Revision 4.
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.
I concluded that the RRDL’s LC 22 arrangements did not align with the relevant good practice outlined within ONR TIG for LC 22. Four findings were raised from the inspection:
- Finding 1: RRDL to review the categorisation scheme within their arrangements to ensure novel and complex modifications, while low in radiological consequence, receive an appropriate level of independent peer review, via the nuclear safety committee, and regulatory oversight prior to implementation.
- Finding 2: RRDL to review the scope, structure and responsibilities within CP/NUC/2/066 Annex G on the safety justification process. This should ensure the process is systematic with clear ownership.
- Finding 3: RRDL to review the arrangements used for the status of modifications, and to ensure an appropriate scheme is in place i.e. ‘Open, Approved, Implemented, Closed’.
- Finding 4: RRDL to review supporting arrangements for the Safety Justification process. This includes the use of a template for the safety justification documentation and the effective use of hold points within the programme.
At the time of the inspection the scope of activities being undertaken upon the nuclear licenced site have a low radiological hazard associated with them (referred to as Submarine Dismantling Project Phase 1). It is my opinion that the modifications being undertaken, even if inadequately conceived or executed, would not lead to a serious risk of a radiological hazard to either the operators or the public. However, development of Phase 2 of the Submarine Dismantling Project is now underway. Phase 2 represents an increase in radiological hazard associated with the activities, including undertaking of novel and complex operations. Therefore this intervention is timely in ensuring the licensee’s arrangements are adequate and fit-for-purpose for current operations and to protect against potential latent errors in Phase 2 operations.
Conclusion of Intervention
On the basis of the evidence sampled at the time of the inspection, the licensee’s arrangements for compliance with Licence Condition 22 (Modification or experiment on existing plant), and their implementation, are inadequate. It is my judgement that a number of shortfalls against identified relevant good practiced have been identified. A single Level 3 Regulatory Issue will be raised to monitor the licensees progress against these. The issue aims to ensure the licensee puts in place adequate arrangements for the categorisation of modifications, for the implementation of the safety justification production process and for tracking of on-going modifications.
Therefore, I consider that an inspection rating of Amber (seek improvement) is merited.