- Site: Devonport
- IR number: 21-172
- Date: February/March 2022
- LC numbers: 36
Executive summary
Purpose of Intervention
This intervention was held at DRDL, Devonport. The purpose was to test DRDL’s arrangements for the management of organisational capability following intelligence gathered from other interactions monitoring organisational accountability changes, structure for delivery of major infrastructure projects and a series of incidents in the principal nuclear facilities on site. It was determined that these shortfalls would be reviewed through the lens of LC36 and nuclear baseline, which is how the licensee demonstrates organisational capability.
The inspection was carried out by a joint team made up of ONR inspectors and DRDL’s internal regulator.
Interventions Carried Out by ONR
The purpose was to determine the adequacy of the implementation of arrangements for management of organisational capability and capacity to deliver safe operations on the licensed site. The inspection focused on:
- the development and maintenance of the nuclear baseline
- the management of the baseline, including vulnerability identification and mitigation management;
- governance and oversight arrangements.
The inspection comprised discussions with DRDL staff, review of arrangements, oversight and governance reports, and sampling of information on electronic databases and other documentation.
The inspection was informed by ONR guidance ‘Function and Content of the Nuclear Baseline’ (NS-TAST-GD-065 Revision 4).
Key Findings, Inspector's Opinions and Reasons for Judgements Made
We identified three areas of good practice during the intervention:
- Plant Managers and Deputy Plant Managers showed good understanding, recognition and management of the nuclear baseline within their facilities including using the baseline to manage their operations in accordance with the site’s LC36 arrangements;
- The controls implemented during the pandemic to demonstrate available resource are still operational, and provide an appropriate way of demonstrating the availability of safe minimum manning;
- Consideration of board capability and competence following appointment of the new DRDL MD.
A number of areas were found where we could not find consistent evidence that DRDL’s Nuclear Baseline could reliably demonstrate sufficient resources are maintained for safe operation across the breadth of activities. These deviations from ONR expectations include:
- Lack of clarity of the governance and ownership structures of the Nuclear Baseline spanning all licensee operations;
- Metrics and performance indicators from DRDL show that high workloads, excessive recorded working hours, singleton positions, vulnerabilities provide indications that the size and make-up of the Nuclear Baseline may not be adequate.
- Nuclear Baseline vulnerabilities (e.g. vacancies) remain unfilled for protracted periods due to issues around prioritisation and friction within the recruitment process. These vulnerabilities then contribute to the issues of high workload and excessive working hours.
- Limited evidence showing how mitigating actions are implemented to address identified shortfalls.
Conclusion of Intervention
Based upon the areas sampled during this intervention, we identified several shortfalls against the requirements of LC36 and DRDL’s ability to demonstrate that adequate resource is maintained to support the full range of activities for which the site is licensed. The operational level controls sampled do provide some confidence that there is no immediate risk to safety arising from organisational shortfalls. Furthermore, we judge that the governance arrangements provided for assurance to the site that LC36 is being appropriately managed are not effective.
We judged that an inspection rating of ‘Amber’ (Seek Improvement) was appropriate for this intervention and will seek evidence of DRDL addressing these shortfalls in a timely manner through a Level 3 Regulatory Issue. The rationale for this decision was discussed with the licensee and the decision accepted.