This intervention was to sample the effectiveness of the Independent Nuclear Oversight (INO) function at Devonport Royal Dockyard Limited (DRDL) Devonport site, in accordance with ONR’s regulatory strategy for the Devonport site.
The intervention considered DRDL organisational capability and capacity within the INO 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 licensees. It follows the same approach as previously used 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 inspection was primarily conducted using the following guide: Challenge Culture, Independent Challenge Capability (including an Internal Regulation function) and the Provision of Nuclear Safety Advice, NS-TAST-GD-080 – Rev 2.
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 Nuclear Oversight and Advice Organisation subset (Assurance Directorate), which included relevant Directors, Senior Operations, Chairs of key Authorisation Groups, Licence Condition Owners, Front-line Delivery and the Independent Nuclear Assurance (INA) functional line.
On the basis of the areas sampled during the intervention, the ONR inspectors judged that the effectiveness of the INO team in providing independent challenge, assurance and nuclear safety advice to DRDL had improved since the last ONR INA intervention in 2018. However, issues remain with respect to the organisational capability of the INO function and their ability to effectively construct and implement the inspection and surveillance programme.
Areas of strength were identified by ONR during the intervention and these included: establishment of a written mandate for the INO function, carrying out learning / benchmarking activities with other licensees, and utilising an effective project management approach for the delivery of INO improvements.
Areas for improvement (regulatory observations) were identified by ONR during the intervention and these included: strengthening the INO organisational capability through recruitment and competency development, delivering an improved risk-based approach for the inspection and surveillance programme, improving visibility and completion of INO related actions, and robust communication of the mandate and role of the INO function at all levels in the organisation. Strengthening the INO organisational capability will provide the foundation for delivering many of the required improvements, and is therefore the highest priority area for attention.
The ONR inspectors considered the effectiveness of the INO function in providing nuclear safety assurance and advice to the DRDL Board as Amber. There are gaps in the INO organisational capability which are affecting the ability of the licensee to deliver an effective inspection and surveillance programme. DRDL has recognised these issues and has established a recruitment and development programme for the INO function. Progress has been made in establishing a written mandate for the INO function, and communication of the mandate and role of the INO function at all levels in the organisation is required. ONR inspectors will monitor progress over the next 6 months and will undertake a further regulatory engagement in the first quarter of 2020.