Office for Nuclear Regulation

Devonport Licence Conditions 24 and 26 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) 24 compliance inspection within 9 Dock and 15 Dock targeting improvements to instructions made in response to crane trip events at 9 Dock and 15 Dock in August and September 2020 (INF1s 2020/599 and 2020/715).

I also conducted a Licence LC 26 Compliance Inspection within 9 Dock to assess DRDL’s implementation of control and supervision against relevant good practice (RGP).

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.

DRDL has responded positively to the crane trip events by providing additional information and guidance to staff which should facilitate improved human performance in the short term. 

It is my opinion that the operating instructions provide an incomplete description of the operating limits and conditions for crane operations.  Furthermore, the lift plan templates did not specifically prompt the recording of information expected as Lifting Operations and Lifting Equipment Regulations 1998 (LOLER) good practice and safety case compliance. Therefore, further improvements are required, specifically with respect to format and content of lift plans and operating instructions, to secure these improvements for the future and demonstrate risk is reduced So Far As Is Reasonably Practicable (SFAIRP).  I will raise two level three regulatory issues to seek the necessary improvements.

DRDL has implemented a new briefing structure from the Sustained Operational Excellence (SOE) initiative with an associated Daily Stand-up Meeting (DSUM).  ONR observed a DSUM briefing which was well structured with clear communication of key information relevant to safety.

However, the inspection found that this new briefing structure does not integrate effectively with existing DRDL arrangements, specifically the Plan of the Day (PLOD), to ensure a wholly systematic approach to safety.  It was not clear how information flowed between the DSUM and PLOD and onward to the operatives or workers.  The DSUM and PLOD are key meetings for maintaining situational awareness, yet the purpose and intent of the meetings was not documented, for instance through Terms of Reference (ToR). I judged that there is also a gap to good practice with respect to how the situational awareness provided by the PLOD is communicated to persons who have already been set to work. It is my opinion that DRDL should document the systematic approach to control and supervision of work through the DSUM and PLOD and review how it communicates safety-related information to confirm that its content facilitates easy and accurate comprehension by end users thus minimising risks arising from human error.  I will raise two further level three regulatory issues to seek improvement.

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

No shortfalls or issues were found which significantly affect nuclear safety or were judged to be of such regulatory concern as to require immediate action. 

Overall, I judged that the licensee’s arrangements for LC 24 and LC 26 have not been implemented in a manner that meet regulatory expectations with multiple shortfalls against RGP observed.  On the basis of evidence obtained during this inspection, I have given an inspection rating of amber LC24 (operating instructions) and LC26 (control and supervision of operations) to seek improvement.  Regulatory issues will be raised to oversee delivery of the necessary improvements.

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.