Office for Nuclear Regulation

Devonport Royal Dockyard – Inspection ID: 51978

Date(s) of inspection

  • November 2023

Executive summary

Aim of inspection

This intervention reviewed and examined DRDL’s arrangements for recording, investigating, and reporting incidents on site (Licence Condition 7 – Incidents on Site). This is a follow-up inspection from the September 2021 inspection which resulted in an Enforcement Letter and associated regulatory issue.

DRDL have delivered an improvement plan in relation to the regulatory issue, and this inspection is to provide evidence to ONR that the enforcement letter has been adequately addressed by DRDL.

Subject(s) of inspection

  • LC7 – Incidents on the site – Rating: Green
  • MHSWR – Rating: Green

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, and identified as a result of extant enforcement action on the site, a Licence Condition (LC) 7 compliance inspection was undertaken at Devonport, as planned, on 14 and 15 November.

The regulatory outcome sought was that in relation to LC7 – Incidents on the site and MHSWR Regulation 5 ‘Health and Safety Arrangements’ the improvements put in place by DRDL in response to the enforcement letter (ONR-EL-22-012) and the regulatory issue (RI-10996) provide ONR with confidence that:

  1. DRDL can adequately record, investigate, and report incidents on site; in particular the screening and sentencing of incidents, assigning incidents to dedicated investigators, carrying out sufficient root cause analysis, effective implementing corrective actions, regular reviewing status of those actions and closing them off in a timely manner.
  2. The roles and responsibilities are clearly articulated and understood by responsible individuals.
  3. There is a suitable and sufficient training programme implemented to support those with roles and responsibilities.
  4. DRDL self-assessment of compliance is developed and delivered.
  5. Analysis of significant events or group of events or trends is undertaken and reviewed on a regular basis, conclusions verified and recommended corrective actions from the analysis occurs.

ONR carried out this intervention jointly with DRDL’s Independent Nuclear Oversight (INO) inspector as internal advice had been given on this topic. This intervention was carried out by sampling and examining the written arrangements that DRDL have in place to record, investigate, and report incidents on site against relevant good practice; by sampling key roles identified in those arrangements and confirming through discussion the understanding of the role responsibilities by those individuals; by gaining evidence of the DRDL self assessment that has been carried out to date and is planned, and finally; by discussing with members of the senior leadership team at DRDL how the trending information is utilised and gaining evidence of how this has led to learning.

This inspection found that the improvements to the arrangements carried out by DRDL and the focus on the implementation of those arrangements across the organisation had resulted in compliance with LC7 being met and had provided confidence that the compliance gaps identified in the enforcement letter had been adequately closed. On the basis of this inspection, along with the evidence gathered at a routine level 4 regulatory interface meeting for the improvement plan, the enforcement letter can be closed along with the associated regulatory issue. A Green rating is therefore considered appropriate, in accordance with ONR Guide ONR-INSP-GD-064.

Conclusion

This inspection found that the improvements to the arrangements carried out by DRDL and the focus on the implementation of those arrangements across the organisation had resulted in compliance with LC7 being met and had provided confidence that the compliance gaps identified in the enforcement letter had been adequately closed.

On the basis of this inspection, along with the evidence gathered at a routine level 4 regulatory interface meeting for the improvement plan, the enforcement letter can be closed along with the associated regulatory issue. A Green rating is therefore considered appropriate, in accordance with ONR Guide ONR-INSP-GD-064.