This intervention was carried out to sample the effectiveness of the Independent Nuclear Assurance (INA) function at Devonport Royal Dockyard Limited (DRDL). It was undertaken in accordance with ONR’s regulatory strategy for the Devonport site.
The intervention considered DRDL’s organisational capability and capacity within the INA function; its independence to be able to raise issues of concern with senior level staff; the adequacy of advice given and timely response to findings; and to broadly assess the cultural acceptance of challenge within the organisation and the remit/mandate of the function.
This DRDL intervention is part of a series of interventions being undertaken across defence propulsion licensees. It applies a consistent approach and the findings benefit from benchmarking against other similar licensees.
The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.
This intervention was carried out through a series of structured discussions with key personnel from the DRDL Operational Functional oversight organisation (Operations Directorate), and the Independent Oversight and Advice Organisation subset (Assurance Directorate) which included relevant Directors, Senior Operations, Chairs of key Authorisation Groups, Front-line Delivery and the Independent Nuclear Assurance (INA) functional line. The intervention also included observation of an on-going INA inspection and review of the terms of reference for a series of safety committees and authorisation groups in DRDL (TRIM 2018/197860).
From the evidence presented by DRDL during this inspection, I am of the opinion that the challenge function is independent from the other business directorates due to where it sits within the organisation, and that it is additional to operational governance on site.
There is a lack of a clear mandate for the Independent Nuclear Assurance (INA) function from the Executive Team, which has led to a limited understanding of the full role of the function across the organisation which in turn limits the efficiency and effectiveness of INA interventions. Therefore the potential safety benefit is limited.
There was some positive evidence of clear independent advice into the business from key groups on site such as Independent Peer Review (IPR) of safety case documentation, the Nuclear Safety Committee, and radiological waste and radiological protection. There was limited evidence of INA using the regulatory tools available to them; with formal advice being given by the INA function only on one occasion very recently, and a limited number of Operational Readiness Reviews (ORRs), although the trend seems to be improving.
The capability of the INA function has shortfalls in the experience, qualifications and authority of key posts. This is due to a combination of lack of depth of experience and the junior grades of staff.
I consider the effectiveness of the Independent Nuclear Assurance function in providing assurance and advice to the DRDL Board as Amber.