Date(s) of inspection
- November 2023
Aim of inspection
The aim of this inspection was to follow-up on the findings of the the themed safety documentation inspection undertaken in February 2023 and the actions taken by RRDL in relation to the associated regulatory issues (RI-11248 and RI-8280).
This inspection is to provide regulatory confidence that the improvements RRDL have put in place as part of the regulatory issues do address the issues identified with the associated arrangements and the implementation of those arrangements and that improvements are adequate and proportionate to the activities being undertaken on the site.
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
- LC14 – Safety documentation – Rating: Amber
- LC22 – Modification or experiment on existing plant – Rating: Amber
- LC23 – Operating rules – Rating: Amber
Key findings, inspector’s opinions and reasons for judgement made
The Office for Nuclear Regulation (ONR) undertakes all regulatory interventions with the Rosyth nuclear site licensee, RRDL against a strategy defined by the ONR Propulsion Sub-Division. In accordance with that strategy, and identified as a result of findings from a previous inspection and an associated regulatory issue, a themed Safety Documentation follow-up inspection was undertaken at Rosyth, as planned, on 27 and 28 November.
The inspection incorporated the actions taken by RRDL in relation to the associated regulatory issues (RI-11248 and RI-8280) and focused on the following Licence Conditions:
LC 14(1) – make and implement adequate arrangements for the production and assessment of safety cases.
LC22 (1) -make and implement adequate arrangements to control any modification or experiment carried out on any part of the existing plant or processes which may affect safety.
LC22 (4) -aforesaid arrangements shall provide for the classification of modifications or experiments according to their safety significance. The arrangements shall where appropriate divide the modification or experiment into stages. The arrangements shall include a requirement for the provision of adequate documentation to justify the safety of the proposed modification or experiment and shall where appropriate provide for the submission of the documentation to ONR.
LC23(1) – produce an adequate safety case to demonstrate the safety of that operation and to identify the conditions and limits necessary in the interests of safety.
LC23(3) – operations are at all times controlled and carried out in compliance with operating rules.
This intervention was carried out by sampling and examining the draft written arrangements that RRDL have in place in relation to the production and governance of safety documentation against relevant good practice and by sampling key roles identified in those draft arrangements and confirming through discussion their understanding of the role responsibilities by those individuals.
This inspection found that RRDL had made improvements to the written arrangements however these improved arrangements had yet to complete due process and be available via the RRDL business management system. ONR also identified through discussion with individuals with roles and responsibilities in the draft arrangements that there were inconsistencies in views on how the arrangements would be utilised in practice. To address this RRDL plan to pilot the arrangements against the upcoming resin transfer operations, and to get the improved arrangements onto the business management system as soon as possible.
RRDL have made improvements in their written arrangements associated with the production and governance of safety documentation. However, the improved arrangements were at draft at the time of the inspection and had not completed due process. ONR identified improvements to these draft arrangements and they need to be implemented effectively by RRDL.
On the basis of this inspection, the regulatory issue associated with the inspection will remain open until RRDL complete the actions. An amber rating is therefore considered appropriate at this time, in accordance with ONR Guide ONR-INSP-GD-064.