- Site: RRSL
- IR number: 20-004
- Date: May 2020
- LC numbers: 7
Executive summary
Purpose of Intervention
The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Nuclear Fuel Production Plant (NFPP) site licensee, Rolls Royce Submarines Limited (RRSL), against a strategy defined by the ONR Operating Facilities Division and Defence (Propulsion) Sub-Division. In accordance with that Strategy, a Licence Condition compliance inspection of the Core Design and Manufacture (CDM) business unit was carried out, as identified within the planned inspection schedule for NFPP/RRSL.
This planned intervention was conducted as a follow up to ONR’s Licence Condition 7 (LC7) inspection in 2019. (CM9 2019/145280). It was undertaken, remotely due to the COVID 19 restrictions, with the aim of assessing if RRSL is adequately implementing its arrangements for compliance with LC7.
Interventions Carried Out by ONR
LC7 requires RRSL to make and implement adequate arrangements for the notification, recording, investigation and reporting of such incidents occurring on the site. The findings from previous LC7 inspections were taken into consideration when planning this inspection (CM reference: 2019/145280).
I carried out a one-day, remote, compliance inspection of the Contact Shop and Chemical Plant against the requirements of LC7.
The inspection was comprised of a discussion with RRSL staff and an examination of a sample of Contact Shop / Chemical Plant facility documentation, to determine if RRSL’s LC7 arrangements have been adequately implemented. The inspection was carried out against ONR’s guidance on inspection of arrangements and their implementation set out in NS-INSP-GD-007, Revision 4, July 2017, LC7 Incidents on the site.
Explanation of Judgement if Safety System Not Judged to be Adequate
N/A - this was not a System Based Inspection (SBI).
Key Findings, Inspector's Opinions and Reasons for Judgements Made
I observed a number of good practices associated with the implementation of RRSL’s compliance arrangements. These were:
- The implementation of a single, networked pictorial and integrated process tool (tube map) for implementing the LC7 arrangements, which meets current relevant good practice.
- As part of the tube map, RRSL has improved its screening and trending of incidents.
- As part of the tube map RRSL has developed and implemented a new and effective Operational Experience process.
Notwithstanding these positive observations, on balance, from the evidence sampled during this inspection, I judge that RRSL has not made the progress against its LC7 improvement plan that I would have expected and still has significant shortfalls in its arrangements and in its investigation of incidents.
In particular it continues to fall short of ONR’s expectations in the conduct and quality of its investigations. RRSL has already identified and acted to address this shortfall by training and recruiting additional investigators but this has not had time to deliver the performance improvement sough yet. I have therefore assigned an inspection rating of AMBER (Seek Improvement).
I have decided that based on the RRSL improvement plan in place and the additional executive and internal regulatory focus on its delivery that the extant level 3 regulatory issue remains adequate to address the significant shortfalls identified. I will reinforce this by reviewing RRSL progress against this plan on a monthly basis. Further escalation to level 2 will be considered if progress is not adequate.
No matters were identified as requiring immediate regulatory attention during the conduct of the compliance inspection.
Conclusion of Intervention
The inspection findings were shared with, and accepted by, RRSL as part of routine inspection feedback. I will follow up RRSL’s progress against the level 3 issue on a monthly basis as part of my normal regulatory duties. I have raised an additional level 4 regulatory issue to ensure that the identified shortfall in this inspection is effectively remedied promptly.