- Site: RRSL
- IR number: 21-004
- Date: April 2021
- LC numbers: 7, 22
Executive summary
Purpose of Intervention
The purpose of this intervention was to evaluate the adequacy of Rolls-Royce Submarines Limited’s (RRSL) arrangements for (and implementation thereof) Site Licence Conditions (LC) 7 (‘Incidents on the site’) and 22 (‘Modification or experiment on existing plant’) at the Raynesway nuclear licensed sites .
Interventions Carried Out by ONR
Both inspections were conducted by the ONR Nominated Site Inspector for the Raynesway sites. The LC7 inspection was conducted on site, whilst the LC22 inspection was conducted remotely. Both inspections aimed to be ‘broad and shallow’, to enable the site inspector to gain familiarity with the arrangements and provide a judgement of the overall situation with respect to each Licence Condition. Alongside that approach, targeted evidence against relevant existing regulatory issues was also sought.
Whilst on site, observations on the site’s coronavirus controls were also made.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
LC7 Inspection
Though I saw sufficient evidence to have confidence that RRSL’s Operational Experience process (the principal means of compliance with LC7) has improved since an AMBER inspection rating was returned in 2019, I identified that shortfalls in regulatory expectations with regard to robust auditable trails, setting and completion of effective actions, and timely delivery of investigations are still evident.
RRSL is planning to implement revised arrangements in the next month, which should address some of the shortfalls seen. Improvements in other aspects (e.g. use of causal codes in trending, appropriate reduction in the levels of governance) are expected to continue beyond that.
LC22 Inspection
RRSL has been aware of shortfalls in the LC22 arrangements since the previous ONR inspection in June 2019. There has been little implemented progress thus far and though the coronavirus pandemic is noted, it does not fully excuse the delay. However, RRSL shared advanced drafts of the new arrangements for the LC22 process, which form a part of a holistic approach to improvement of arrangements for LCs 19-22.
I consider the current arrangements to be complex, being spread across many documents; in my opinion, recent events show that RRSL needs to focus on the recognition of what constitutes a change to ensure the correct process is followed. Inspection of selected completed modification forms showed that if the process is followed correctly, a good result can be achieved.
Conclusion of Intervention
Based on the samples inspected, I rate both the LC7 and the LC22 inspections as AMBER – ‘Seek Improvement’. These ratings are in line with the established ONR guidance:
- “Significant shortfall against an identified relevant good practice when compared with appropriate benchmarks.”
Follow up inspections on LC7 (October 2021) and LC22 (November 2021) are planned to monitor the improvements RRSL is planning to implement. Existing Regulatory Issues 8119 (for LC7) and 7286 (for LC22) will be updated with the findings from these inspections.