Executive summary
Date(s) of inspection: November 2024
Aim of inspection
To judge the adequacy of RRDL's response to Regulatory Issues RI-11248 and RI-12015 associated with the adequacy of its safety documentation production and governance arrangements made under Licence Conditions (LC) 13, 14 and 22.
Subject(s) of inspection
- LC13 - Nuclear safety committee - Rating: Green
- 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) 13, 14 and 22, for both current activities as well as readiness for 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-013, 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 13, 14 and 22.
Conclusion
Based on the findings of the intervention, ONR considers that RRDL has adequate arrangements for compliance with LC 13 ,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).
- there is an established NSC for consideration and advice for all matters required by or under the condition (LC 13).
It is therefore judged that an inspection rating of Green (No formal action) 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 several areas for further improvement, which have subsequently been communicated to RRDL. As part of the inspection we also sampled evidence of progress against regulatory issue RI-11248 associated with RRDL's LC 14 and 22 arrangements, and RI-12015 associated with RRDL's holistic review and update of its broader LC compliance arrangements. With respect to RI-11248, we judged that RRDL provided satisfactory evidence to close all four actions - see below and RI-11248 action closure statements for specific details. For RI-12015, RRDL has made good progress against the actions with an anticipated completion of Q1 2025. We agreed to follow this up via a future intervention once RRDL considers the actions as complete.