Executive summary
Date(s) of inspection: July 2024
Aim of inspection
To judge the adequacy of DRDL’s implementation of its arrangements made under LC 6 (Documents, records, authorities and certificates) and LC 21 (Commissioning) for Phase 2 inactive commissioning of the 14 Dock Reactor Access House (RAH), which includes the RAH Crane, RAH Travel and Alignment system, and RAH P1 and P2 Protection Systems. Both LC 6 and LC 21 include the requirement for licensees to make and implement adequate arrangements to satisfy the requirements of the condition. We will sample evidence of DRDL’s implementation of its arrangements made under these conditions.
Subject(s) of inspection
- LC6 - Documents, records, authorities and certificates - Rating: Green
- LC21 - Commissioning - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
In accordance with its arrangements Devonport Royal Dockyard Limited's (DRDL) has produced a pre-commissioning safety report/strategy to justify commencing inactive commissioning of the 14 Dock Reactor Access House (RAH). Whilst there is no formal regulatory hold point on commencement of this activity, there is a future hold point on DRDL commencing defuel and maintenance of its Laid Up Submarines (LUSMs) in the Submarine Refit Complex (SRC) 14 Dock using the RAH. The purpose of this inspection is to gain assurance of DRDL's compliance with implementation of its arrangements and the readiness of the people, process and plant to undertake these activities. This inspection will inform DRDL's ability to safely deliver these activities and provide regulatory intelligence of potential areas to target for ONR's permissioning assessment of the future plant safety case submission.
The intervention was undertaken and rated against published guidance on regulatory expectations, as described in ONR inspection guides ONR-INSP-GD-006, -021 and -064. Based on the evidence sampled at the time of the intervention against DRDL's arrangements and documentation, and regulatory guidance ONR judged that DRDL adequately demonstrated that:
- Where appropriate, the commissioning is divided into stages;
- There is adequate safety documentation to justify the safety of the commissioning;
- Suitably qualified person or persons (SQEP) have been appointed for, controlling, witnessing, recording and assessing the results of any commissioning tests;
- There are (or is the provision to make) adequate records to demonstrate compliance with LC 21;
- There are adequate arrangements to ensure that every commissioning document required, every record made and every certificate issued is preserved for 30 years.
Based on the above ONR considers that DRDL has implemented adequately its arrangements for compliance with LC 6 and LC 21.
Conclusion
Based on the findings of the intervention, ONR considers that DRDL has implemented adequately its arrangements for compliance with LC 6 and LC 21. 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.