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Rosyth - Inspection ID: 50899

  • Site: Rosyth
  • Inspection ID: 50899
  • Date: August 2022
  • LC numbers: N/A

Executive summary

Purpose of intervention

ONR is inspecting to gain confidence that RRDL have made the necessary improvement to their LC 10 and 12 arrangements and their implementation, such that they are able to demonstrate that individuals undertaking nuclear safety important roles are suitably qualified and experienced. Additionally, ONR is looking to gain confidence that RRDL have an adequate improvement programme for any residual improvements necessary to support phase 2 operations.

Subject(s) of inspection 

  • LC12 - Duly authorised and other suitably qualified and  experienced persons - (Rating: Amber)
  • LC10 - Training - (Rating: Green)

Key findings

In accordance with the Office for Nuclear Regulation’s (ONR’s) regulatory approach, we undertake a series of planned inspections seeking to determine compliance against the conditions of the site licence.

This inspection focussed on the implementation of Rosyth Royal Dockyard Ltd. (RRDL) arrangements for compliance with Licence Condition (LC) 10 (Training) and LC 12 (Duly authorised and other suitably qualified and experienced persons (SQEP)).

Interventions carried out by ONR

The planned LC10 and 12 compliance inspection was carried out on 3 August 2022 on the RRDL site. During the inspection, we gained evidence of how RRDL manage and track the training and competence of individuals whose role is necessary for nuclear safety. This was a follow-up inspection to gather evidence for an extant LC10 and LC12 related regulatory issue. Specifically, we:

  • Explored the adequacy of the written arrangements for LC10 and 12 in meeting regulatory expectations
  • Inspected a sample of role profiles and training and competency records for individuals on the nuclear baseline at different levels of the organisation
  • Discussed the arrangements for competency management and how they are used in practice with a sample of role holders on the nuclear baseline.
  • Explored how changes to the nuclear baseline are managed and tracked using the recent creation and appointment of a senior role.

Key findings, Inspector's opinions and reasons for judgements made

During the inspection we identified several positive aspects: the reformation of the Nuclear Training Review Committee, the quality of the competency records and the enabling conversations on competence between individuals and their line managers. We have seen a significant improvement in relation to RRDL's arrangements for training and competency and their implementation.

The work to develop DAP arrangements has been delayed and currently there are no arrangements in place that identify the criteria for when a DAP would be required or how they would be appointed. This needs to be resolved ahead of higher hazard activities commencing on the site.

Conclusion of the intervention

We judged that there has been significant improvement in the training arrangements and that these generally met relevant good practice (NS-INSP-GD-010 – Training). We concluded that the LC10 arrangements were being well implemented and that there was significant benefit to the systematic approach being applied. We awarded a rating for LC10 - Training of Green (no formal action) on this basis.

As the DAP arrangements are not in place we judged that there remains a significant shortfall against an identified relevant good practice when compared with appropriate benchmarks (specificallyNS-INSP-GD-012 – Duly Authorised and other Suitably Qualified and Experienced Personnel). We awarded a rating for LC12 -Duly authorised and other suitably qualified and experienced personsof Amber (Seek Improvement) on this basis. There is a regulatory issue already in place that remains a suitable regulatory tool for actioning and monitoring improvements in this area.

Judgements made

We judged that there has been significant improvement in the training arrangements and that these generally met relevant good practice (NS-INSP-GD-010 – Training). We concluded that the LC10 arrangements were being well implemented and that there was significant benefit to the systematic approach being applied. We awarded a rating for LC10 - Training of Green (no formal action) on this basis.

As the DAP arrangements are not in place we judged that there remains a significant shortfall against an identified relevant good practice when compared with appropriate benchmarks (specificallyNS-INSP-GD-012 – Duly Authorised and other Suitably Qualified and Experienced Personnel). We awarded a rating for LC12 -Duly authorised and other suitably qualified and experienced personsof Amber (Seek Improvement) on this basis. There is a regulatory issue already in place that remains a suitable regulatory tool for actioning and monitoring improvements in this area.