ONR examined the arrangements Devonport Royal Dockyard Limited (DRDL) has put in place to manage its organisational capability in accordance with the requirements of Licence Condition (LC) 36. This was a further planned inspection, following inspections carried out in 2015, where DRDL’s LC36 arrangements were judged to have a number of shortfalls compared to relevant good practice.
ONR examined the nuclear baseline, DRDL demonstrated that it has identified the resource levels needed to carry out day-to-day operational activities. DRDL also understands how its actual resource levels compare to these through the utilisation of the nuclear baseline management tool and vulnerability metrics. These operational levels are not, in most cases, the minimum levels necessary to operate safely and therefore where actual staffing levels fall below operational baseline levels it is unclear whether or not minimum staffing levels have been maintained. Notwithstanding this, ONR found no evidence which would indicate that DRDL did not have adequate human resources to ensure the safe operation of its nuclear activities.
DRDL has made progress in identifying nuclear safety related roles for inclusion on the nuclear baseline and recognises that further work is required before all roles are identified and recorded on the baseline. ONR identified a number of additional roles for inclusion on the baseline and DRDL should incorporate these into its improvement programme.
DRDL does not currently have succession planning arrangements or succession plans for individual holders of nuclear safety related roles. DRDL recognises the importance of addressing this shortfall and intends to implement new arrangements during 2018.
Whilst ONR found no evidence which would indicate that DRDL did not have adequate human resources to ensure the safe operation of the licensed site, it is the ONR inspector’s judgement that further work is required before DRDL is able to adequately demonstrate the adequacy of its human resources. Further work is also required to ensure that all nuclear safety related roles are identified on the nuclear baseline. DRDL should also establish and implement succession planning arrangements in a proportionate and targeted manner to ensure that where vulnerabilities are identified, succession plans are in place.
These three shortfalls form the rationale for the judgement: ONR continues to seek improvement in DRDL’s LC36 arrangements and their implementation. ONR notes the significant progress that DRDL has made since the last inspection and there is now a greater degree of regulatory confidence in DRDL’s ability to make the improvements necessary to address the shortfalls. ONR will continue to engage with DRDL throughout 2017 and a further inspection will be conducted in February 2018.
It is ONR’s expectation that the shortfalls identified during this inspection are addressed prior to the next inspection planned in early 2018. DRDL plans to close-down the LC36 improvement project, currently a work-stream of the Nuclear Safety Improvement Programme, in December 2016. ONR will seek assurance from DRDL that the organisational capability team is adequately resourced to deliver the required improvements, given the scale of the work remaining and the importance of an enduring solution, and that adequate Board-level governance and oversight is maintained.