- Site: Rosyth
- IR number: 20-024
- Date: July 2020
- LC numbers: 22
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):
- 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.
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:
- Regarding ONR finding 1, RRDL has reviewed their modification categorisation scheme, and they have sought relevant good practice from other licensees. The proposed revision to the LC 22 arrangements does seek to address modification novelty and complexity in a manner which I judge to be an appropriate response to ONR finding 1.
- Regarding ONR finding 2, RRDL has reviewed the scope, structure and responsibilities within their safety justification process. The proposed revision to the arrangements shows improvement in the clarity of both the process flow and ownership aspects, which I judge to be an appropriate response to ONR finding 2.
- Regarding ONR finding 3, RRDL has reviewed their arrangements used for the status of modifications. The licensee has implemented an improved status scheme for the safety case related register, and changes to project management policy is progress, which I judge will be an appropriate response to ONR finding 3.
- Regarding ONR finding 4, RRDL has reviewed the supporting arrangements for the safety justification process. A supporting template is under development, and a gated project lifecycle which supports suitable hold points is proposed, both of which I judge to be appropriate responses to ONR finding 4.
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.