Date(s) of inspection:
- October 2022
Aim of inspection
The purpose of the intervention was for the ONR to inspect and determine the adequacy of implementation of DRDL formal arrangements for compliance with LC11 via an on-site demonstration of their emergency arrangements during a Level 1 exercise.
Subject(s) of inspection
- LC11 – Emergency arrangements – Rating – Amber
Key findings, inspector’s opinions and reasons for judgement made
The Office for Nuclear Regulation (ONR) undertakes all regulatory interventions with the Devonport nuclear site licensee, DRDL against a strategy defined by the ONR Propulsion sub-Division. In accordance with that strategy, a Licence Condition (LC) 11 compliance inspection was undertaken at Devonport, as planned, on 26 October.
The purpose of the intervention was for the ONR to inspect and determine the adequacy of implementation of DRDL formal arrangements for compliance with LC11 via an on-site demonstration of its emergency arrangements during a Level 1 exercise.
The intervention was undertaken and rated against published guidance on ONR’s expectations, as described in the technical inspection guides (TIGs), which can be found at Office for Nuclear Regulation (ONR) Compliance inspection – Technical inspection guides. Specifically, this included NS-INSP-GD-011 and ONR-INSP-GD-064.
Based on the evidence sampled at the time of the intervention against DRDL’s LC11 arrangements and ONR’s guidance, I consider that DRDL did not adequately demonstrate its arrangements across the areas sampled. I was satisfied that the exercise scenario was realistic and sufficiently challenging.
It is my opinion that the Level 1 emergency response demonstration exercise did not provide adequate evidence of implementation of the established emergency arrangements on the Devonport site, in respect of LC11. An Amber rating is therefore considered appropriate, in accordance with ONR Guide ONR-INSP-GD-064. As a result of this rating a redemonstration, of those areas observed on the day not to meet the sites’ arrangements, has been identified as the appropriate response required by the site.
ONR inspectors made observations at various locations during the exercise. Summary of the most significant issues on the day which impacted the DRDL’s ability to satisfactorily demonstrate their emergency arrangements were:
- Cascade Call Out – did not deliver the required competent persons to the site in suitable timeframes.
- Casualty Recovery – Confusion on roles that led to delays in recovery.
- Personnel Accountancy – Inconsistency in numbers sheltering not challenged or verified throughout the exercise.
- EMHQ – issues with the capacity and capability observed.
- Transmission and sharing of information – multiple examples of different components of the response being unaware of the current status or being informed a long time after the fact.
The Defence Nuclear Safety Regulator (DNSR) also assessed the exercise demonstration and provided aligned evidence/observations, consistent with the approach of joined up regulation as did the DRDL Independent Nuclear Oversight team.
The prioritised observations were fed back to DRDL as part of the “hot wash-up” meeting along with the judgement. This judgement concluded that based on the observations on the day, that the demonstration did not satisfactorily demonstrate the sites emergency arrangements and that a further test would be required.
The detailed comments of the inspection team have been sent to DRDL Head of EP&R. In terms of timing of a redemonstration, this is a discussion that is to be had with DRDL.