LC7 compliance inspection
- Site: Rosyth
- IR number: 19-035
- Date: June 2019
- LC numbers: 7
Purpose of Intervention
This intervention at the Rosyth Royal Dockyard Limited (RRDL) licensed site was undertaken as part of the 2019/20 intervention plan and propulsion sub-division strategy.
Interventions Carried Out by ONR
I conducted a Licence Condition (LC) 07 (“Incidents on the site”) compliance inspection. I focused on the implementation of the licensee’s arrangements. This involved examination of relevant licensee documentation and incident management system, targeted discussions with relevant members of the licensee’s staff and inspection of the Active Waste Accumulation Facility (AWAF).
I assessed compliance against:
- LC7 compliance – ONR Technical Inspection Guides (TIG), principally NS-INSP-GD-007.
- IAEA – Specific Safety Guide (SSG) 50: Operating Experience Feedback for Nuclear Installations.
Explanation of Judgement if Safety System Not Judged to be Adequate
Key Findings, Inspector's Opinions and Reasons for Judgements Made
There were a number of areas of industry good practice observed at the site, including:
- The Airsweb incident management system has been in place since 2013. Regular use of Airsweb by staff and contractors was evident.
- Chain of reporting is understood by staff members.
- The process of registering, initial categorising, sentencing, investigation and close-out cycle is adequately followed; recognising this done via the site wide (conventional health and safety) arrangements.
- Just Not Right / Just Culture provides opportunities for staff at all levels to report incidents, near-misses and non-conformances.
The following shortfalls identified during the compliance inspection and will be addressed through the raising of a regulatory issue.
- The documents defining the LC7 arrangements are significantly out of date. ONR was provided with a revision dated from June 2015, which was the same revision provided at the 2017 LC7 compliance inspection. Information such as ONR emergency contact details and job roles were invalid, and references were to out of date legislation.
- There was an absence of evaluation and corrective action review meetings. Review and closure of incidents is being completed by individuals. It was not evident that corrective actions had been adequately reviewed within teams to check whether the corrective action met the intent, and whether reoccurrence was likely to be prevented.
- There is no guidance aligning site events to ONR reporting criteria. This makes the process subjective and it is carried out by singleton resource which has potential to lead to missed or incorrect reporting.
- The level of detail captured in the recorded actions and action responses should be improved within the incident management system, Airsweb. These should include links or attachments which give the evidence that an action is demonstrably complete.
- The organisational capability should be improved, in particular reliance on singleton roles such as the Nuclear Assurance Manager and Design Safety Manager. The key concern is workload on individuals and this will become more critical as the site moves onto stage 2 of submarine dismantling operations.
The following was recommended as an area for improvement:
- The site has a number of event reporting arrangements, which are distilled from a corporate level and then categorised at a business unit level. To reduce likelihood of confusion and workload, it is recommended that the site should improve the alignment of nuclear and radiological arrangements to site wide arrangements.
I undertook a physical inspection at the AWAF in support of the compliance inspection. I reviewed the implementation status of a number of corrective actions and checked staff members’ understanding of the LC7 reporting arrangements, and their understanding of how learning is shared on site.
Based on the sampling that I undertook as part of the inspection, I have confidence that RRDL will continue to deliver the required enhancements to the LC7 compliance arrangements in a timely manner. This confidence is built on the self-identification that RRDL has already demonstrated, and the delivery to date of improvements to the reporting arrangements.
Conclusion of Intervention
Based on my inspection of the licensee’s arrangements for compliance with LC 07, I have identified areas of compliance where shortfalls still exist against relevant good practice. Whilst there are elements of good practice, the arrangements do not demonstrate compliance across all of the requirements of LC 07. Therefore I judge that an AMBER rating is merited.
Whilst a rating of AMBER would typically require a level 3 regulatory issue to be raised, I consider this to be disproportionate as the licensee has self-identified many of the inspection findings and continues to work to correct these. I therefore propose a level 4 regulatory issue to allow the work to be monitored through routine regulatory business.