This report covers attendance at the Devonport site for routine engagement and inspection activity. The inspection was undertaken as part of a series of planned interventions supporting ONR’s DRDL Intervention strategy.
ONR carried out planned LC6 (Documents, Records, Authorities and Certificates), LC17 (Management Systems) and LC25 (Operational Records) compliance inspections on site.
For LC6 ONR sampled the arrangements for the production and retention of Lifetime Quality Records (LTQRs) at a corporate and project level. The corporate level arrangements are currently undergoing review prior to final sanction by DRDL. The project arrangements and implementation were sampled for a 9 Dock structure that was important to nuclear safety. It was found that the project was operating to relevant good practice.
For LC17 ONR sampled the recently revised arrangements relating to project initiation and investment, to ensure there was a robust link between the project initiation and plant modification processes where there is a potential impact on safety. The auditable trail within the new process was found to be incomplete in the two samples that ONR examined.
For LC25 ONR noted that there had been further slippage against an improvement plan for the production of corporate and local arrangements for operational records. ONR gained confidence in DRDL’s record management following examination of records that were sampled at a facility level for safety significant assets.
Further interventions will be carried out so that ONR can assure itself that the arrangements and implementation of LC17 and LC25 are adequate.
ONR has raised a regulatory issue which will monitor the required improvements to the implementation of DRDL’s project governance (LC17).
ONR will send a letter to DRDL which will detail our expectations for an increased pace of delivery against DRDLs improvement plan for LC25.
ONR shall follow the progress of the corporate level arrangements for LTQRs to gain comfort that the 9 Dock sample project was a representative sample.