This intervention at the Devonport Royal Dockyard Limited (DRDL) licensed site was undertaken as part of the 2016/17 intervention plan and propulsion sub-programme strategy.
As part of this intervention we examined DRDL's licence condition (LC) arrangements for operational records. I also conducted level 4 regulatory meetings with SRC and Site Services plant management teams.
We are of the opinion that the top level management system policy, process and supporting guidance documents for Nuclear Document Management are adequate. However, we found that the implementation of these arrangements within the organisation is inconsistent and there has been limited stakeholder engagement in the process.
Individuals who hold the post of Responsible Manager were aware of their responsibilities for records management. However, local arrangements had not been established in all areas sampled in accordance with DRDL's Nuclear Document Management process.
An area of good practice was observed with the Health Physics records. Evidence was provided of implementation of the full process described in DRDL's arrangements, and the backlog of legacy records has significantly reduced.
Due to the inconsistency of local implementation we are not convinced that the licensee is capturing, archiving and has the ability to retrieve all operational records in compliance with the requirements of LC25.
We judged that the licensee's arrangements for ensuring that adequate records are made of the operation, inspection and maintenance of any plant which may affect safety require improvement. A regulatory action has been placed on the licensee to address these shortfalls against relevant good practice.