Executive summary
Date(s) of inspection:
Aim of inspection
The objective of the inspection was to establish whether RRDL has adequate processes in place to support development of safety cases for the Submarine Disposal Project Phase II and that there is evidence the processes are currently delivering adequate safety cases for the Resin Transfer operations.
This targeted safety documentation inspection covered Licence Condition, (LC)14 - Safety Documentation, LC 23 - Operating Rules and LC 26 - Control and supervision of operations at Rosyth Royal Dockyard Limited (RRDL). The purpose was to assess the adequacy of the arrangements that the site have in place for the production and assessment of safety cases, consisting of documentation to justify safety during the phases of activities on the licensed site.
In relation to these arrangements, we assessed how the safety case demonstrates safety and identifies the conditions and limits necessary in the interests of safety, and from the safety documentation how RRDL ensured adequate control and supervision for their activities which may affect safety.
This inspection is judged as proportionate and targeted as the site have commenced a safety significant design project (Submarine Disposal Project Phase II) and are preparing to carry out Resin Transfer operations in the Active Waste Accumulation Facility.
Subject(s) of inspection
- LC 14 - Safety documentation - Rating: Amber
- LC 22 - Modification or experiment on existing plant - Rating: Amber
- LC 23 - Operating rules - Rating: Amber
- LC 26 - Control and supervision of operations - Rating: Green
- Overall Inspection Rating - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
Two ONR inspectors conducted a targeted compliance inspection of safety documentation at the Rosyth Royal Dockyard licensed site. As the projects sampled are both under the sites modification arrangements we also sampled the sites LC22 - Modification or experiment on existing plant arrangements and implementation and this element was added to the inspection scope.
The inspection comprised of a review of relevant documentation, discussion of the arrangements with personnel who own those arrangements and with individuals who have responsibilities identified within them and are currently implementing the arrangements for the projects sampled.
The inspection identified several significant disconnects between the written arrangements relating to the production, oversight and governance of safety documentation, in relation to the modifications sampled during the inspection. We identified that there were adequate arrangements and implementation of those arrangements in relation to control of work on the site.
We judged an overall inspection rating of amber was appropriate for this inspection on the basis of RRDL's failure to implement or meet the site’s compliance arrangements.
Conclusion
The inspection findings were presented to Rosyth Royal Dockyard at the close of the inspection.
The inspection identified several significant disconnects between the written arrangements relating to the production, oversight and governance of safety documentation, in relation to the modifications sampled during the inspection. We identified that there were adequate arrangements and implementation of those arrangements in relation to control of work on the site.
We judged an overall inspection rating of amber was appropriate for this inspection on the basis of RRDL's failure to implement or meet the sites compliance arrangements.
We propose a level 3 regulatory issue related to the safety documentation production and governance findings of this inspection. A level 4 regulatory issue exists for improvements to RRDLs Operating Rule arrangements, on the findings from this inspection we will update this regulatory issue to reflect the proportionality issue identified. We will track these regulatory issues as part of routine inspection activities on the site.