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 Periodic Review of Safety and sampled their implementation. I also conducted a level 4 regulatory meetings with SRC plant management team and engagement on safety case improvements.
DRDL has improved its arrangements for periodic review and has addressed the majority of the shortfalls identified in ONR correspondence. DRDL has introduced a Periodic Review of Safety (PRS) Governance Board to monitor programme performance and action close-out. This meeting provides management attention to a number of legacy performance issues.
We sampled a completed PRS document and found it had limited scope and was only completed on a specific plant area within a facility. The safety case was also reviewed separately outside the PRS scope. ONR expects a PRS review to include a comprehensive assessment of the facility's condition, operating experience, safety case and management arrangements and culture.
In addition, the arrangements currently do not include provision for short term or exceptional reviews and do not require consideration of Leadership and Management for Safety. We also found that the Basis for Continued Operations documents are only required to be sent to the safety committee for noting not for consideration and advice. Based upon the evidence we are of the opinion that there is a significant shortfall in the arrangements against ONR's periodic review technical inspection and assessment guides.
We judged that the licensee's arrangements for periodic review require improvement. A regulatory action has been placed on the licensee to address the shortfalls against relevant good practice.