Office for Nuclear Regulation

Management Systems and Quality Management Arrangements (LC17)

Executive summary

Purpose of Intervention

This intervention was conducted at the Devonport Royal Dockyard Ltd (DRDL) licenced site at Plymouth, and was undertaken as part of the 2019/2020 intervention plan (CM9: 2018/170626 refers), and the propulsion sub-division strategy. The planned inspection covered Licence Condition 17 (LC17) ‘Management Systems – Quality Management Arrangements’.

The purpose of Licence Condition 17 (LC17) is to ensure that the licensee establishes and implements management systems which give due priority to safety.

Interventions Carried Out by ONR

I conducted a LC 17 ‘Management Systems –Quality Management Arrangements’, compliance inspection on the implementation of the licensee’s arrangements, which included a sample of the management system arrangements.

The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.

I utilised the following guidance during this inspection:

The intervention involved discussions with DRDL staff and examination of the extant arrangements and their implementation.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable – this was not a Safety System inspection.

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

The licensee’s staff engaged positively during the course of this inspection. During this inspection I have identified good practices and noted observations for management action.

The licensee is improving their existing management system arrangements for LC17 to align with relevant good practice. The LC 17 framework arrangements are yet to be fully developed and implemented and I found specific deficiencies in relation to the arrangements, their implementation and management responsibilities. On this basis LC17 Management Systems – Quality Management Arrangements has been rated as ‘Amber’.

I consider that Regulatory Issue (RI) 6053 –Corrective Action Management cannot be closed out as I identified shortfalls in the management system relating to open actions from internal and external raised findings.

I consider that Regulatory Issue (RI) 6626 - Learning from Experience (LfE) cannot be closed out at this time; some improvements have been made on a particular project, but  a core process for all to use has not been developed . Programmed actions on the development of an LfE process and its implementation have not been completed.

I have recorded additions to Regulatory Issue (RI) 7245 on management leadership and commitment.

Conclusion of Intervention

Based on the evidence sampled during this inspection, I have concluded that an intervention rating of AMBER is appropriate.

I judged that there has been insufficient improvement to the licensee’s management systems for regulatory issue (RI) 6626, on LfE and (RI) 6053 on corrective action management. Both remain open pending further improvement.