Office for Nuclear Regulation

LC36 inspection of DRDL

Executive summary

Purpose of intervention

This intervention, undertaken at the Devonport Royal Dockyard Limited site, was one of a series of inspections planned for 2015/16, and its purpose was to evaluate the licensee’s compliance with Licence Condition (LC) 36: Organisational Capability.

Interventions Carried Out by ONR

ONR’s Nominated Site Inspector, together with the Defence (Propulsion) Programme’s Leadership and Management for Safety Inspector, undertook an inspection on the DRDL licensed site to evaluate the extent to which the licensee complies with LC36.  The inspection was targeted on the revised arrangements for deriving and managing the nuclear baseline, along with the implementation of these arrangements in a pilot area.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable

Key Findings, Inspector's Opinions and Reasons for Judgements Made

A lot of work has been undertaken by DRDL’s LC36 improvement project team and there is evidence of logical thought in developing the arrangements.  The work undertaken by the project team has enabled a greater understanding of the organisational structures, staffing and competencies within the pilot area, as well as highlighting areas of vulnerability.  The derivation of the nuclear baseline has also helped to identify additional roles that are considered to be Duly Authorised Person status.  The newly developed categorisation of roles is an area that is an improvement to the arrangements and a wider view is being taken of roles that may affect nuclear safety.  Notwithstanding this, a number of shortfalls have been identified, some of which are as a result of the pilot not being completed, others as a result of the revised arrangements not meeting ONR’s expectations.  The shortfalls are as follows:

Furthermore, from reviewing the nuclear baseline and developing an understanding of the significance of the vulnerabilities within it, it is ONR’s judgement that within the pilot area there are insufficient human resources, however, DRDL has put in place interim compensatory measures aimed at ensuring compliance with safety limits and conditions, which ONR considers to be acceptable.  ONR judges DRDL’s compliance with LC36 to be significantly below standard.

Conclusion of Intervention

ONR’s inspectors concluded that there are shortfalls with DRDL’s compliance with LC36.  An enforcement letter will be sent to DRDL explaining ONR’s expectations and DRDL will be asked to provide a response with a detailed plan to address the shortfalls.