- Site: Devonport
- IR number: 21-150
- Date: January/February 2022
- LC numbers: 11
Executive summary
Purpose of Intervention
A compliance inspection of Licence Condition 11 (LC11) – Emergency Arrangements was conducted at the Devonport Royal Dockyard Limited (DRDL) licensed site. As DRDL and HMNB Devonport have joint emergency arrangements the inspection involved both DRDL (Babcock) and HMNB Devonport (MoD) arrangements.
Purpose of Intervention
The inspection was undertaken as part of the 2021/22 intervention plan and propulsion sub-division strategy to assess the adequacy of DRDL’s and HMNB Devonport’s joint arrangements for LC11 (Emergency Arrangements). The focus of the inspection was the arguments and evidence presented in response to targeted questions contained within ONR’s Emergency Preparedness and Response Capability Map (EPRCM) requirements. This is a framework used to evaluate emergency planning and response in the context of seven subject areas. ONR aims to evaluate all areas of the EPRCM on each licensed site during a five-year cycle.
The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.
Interventions Carried Out by ONR
During the inspection an inspection team comprising ONR, the Defence Nuclear Safety Regulator (DNSR), DRDL’s Independent Nuclear Oversight (INO) function and the MoD’s INO function sampled a subset of EPRCM questions.
The inspection comprised plant tours, interviews and review of documents provided as evidence for the subset of EPRCM questions sampled.
The inspection team will be referred to as ‘we’ within this report.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
On the basis of the sample we found that whilst DRDL and HMNB Devonport were able to demonstrate adequate compliance with LC11 in some areas, there were areas where more robust demonstration of compliance is required and we therefore rated the inspection ‘Amber – seek improvement’.
Conclusion of Intervention
The inspection findings were presented to DRDL and HMNB Devonport at the close of the inspection. The inspection team identified improvements were required which included the need to demonstrate how planning for and testing of the full range of emergencies is undertaken, a clear understanding of the Nuclear Emergency Response Organisation base line, how training for the Nuclear Emergency Response Organisation is provided, maintained up to date and appropriately recorded, how the emergency facilities and equipment are suitable for both current and future operations and maintenance of up-to-date emergency response documentation.
There were no findings from this inspection that could significantly undermine emergency preparedness and response, or which would result in changes to the planned interventions and inspections of the DRDL licenced site.