Office for Nuclear Regulation

LC 10 and 12 compliance inspection

Executive summary

Purpose of Intervention

This intervention, conducted at the licensee’s (Devonport Royal Dockyard Limited - DRDL) Devonport site, was undertaken as part of the 2020/21 intervention plan and propulsion sub-division strategy.

Interventions Carried Out by ONR

I conducted a Licence Condition (LC) 10 (training) and LC12 (duly authorised and other suitably qualified and experienced persons) compliance Inspection with the inspection focused upon the following purposes:

The visit was also used to undertake an assessment of the adequacy of DRDL’s arrangements for compliance with COVID-19 social distancing and other health protection measures, and the implementation of these measures on site. 

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

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable.

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

No matters were identified as requiring immediate regulatory attention during the conduct of the compliance inspection.

It is my opinion that with respect to the areas sampled, DRDL has adequate arrangements in relation to LC10 and 12. In my opinion DRDL have maintained an effective training and DAP/ASQEP appointment programme through challenges presented by the COVID19 pandemic.  There is a clear process for demonstration of compliance with LC36 minimum baseline manning levels on a daily basis. All personnel interviewed through the intervention were clear on their responsibilities for safety and had sufficient means and ability to discharge these responsibilities.  I identified a number of areas of good practice and in my opinion, there are clear control arrangements in place to ensure that there are sufficient SQEP personnel to ensure that work activities can be conducted safely.

DRDL’s arrangements were judged to be in compliance with current government guidance in relation to working safely during COVID-19 in factories, plants and warehouses. The arrangements were judged to be effectively implemented.

Conclusion of Intervention

Overall I judged that the licensee’s arrangements for LC10 and 12 are adequate and have been appropriately implemented.  On the basis of evidence obtained during the intervention I have given an inspection rating of green for LC10 (training) and LC12 (duly authorised and other suitably qualified and experienced persons).

In relation to COVID19 social distancing and other health protection measures, I judged that the licensee’s arrangements are adequate, in full compliance with government advice and guidance and have been effectively implemented.