- Site: RRSL
- IR number: 21-017
- Date: May 2021
- LC numbers: 11
Executive summary
Purpose of Intervention
The purpose of this intervention was to:
- Undertake a compliance inspection of Rolls-Royce Submarines Limited’s (RRSL) Licence Condition (LC) 11 (Emergency Arrangements), which forms part of the 2021/22 intervention plan and propulsion sub-division strategy.
- Undertake an inspection to gather evidence that RRSL has made sufficient improvements against Improvement Notice ONR-IN-20-02, served in May 2020.
Interventions Carried Out by ONR
A planned LC11 compliance inspection which focused on the duty holder’s demonstration of Emergency Preparedness and Response Capability Map (EPRCM) expectations under outcomes 1-3. The EPRCM framework is used to evaluate emergency planning and response across all the licenced sites to aid consistency and is organised into seven subject areas. ONR aims to evaluate all areas of the EPRCM at the RRSL sites over a five-year cycle.
A planned inspection (nominally against LC23 and LC24) which focused on the improvements RRSL has made against the Improvement Notice ONR-IN-20-02, served in May 2020. The inspection was undertaken in two parts; a desktop session, where RRSL provided a presentation-based narrative, supported by documentary evidence of the improvements made, and a plant-based session where the nominated site inspector had the opportunity to observe the on-plant improvements and question operational staff on their knowledge of the criticality limits.
The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
For the LC11 compliance inspection, I judged that RRSL adequately demonstrated that emergency arrangements were up-to-date, available to all personnel, and included consideration of those facilities about to increase hazardous chemical inventories. Furthermore, adequate training was shown to be available and relevant personnel had been appropriately trained. Whilst RRSL was able to show that it learned from shortcomings in previous emergency exercises, opportunities to improve the rigour of action tracking were apparent.
Through sampling of a relevant safety case, I judged that RRSL adequately demonstrated that activities and processes that have potential for an accident, as well as transient threats, were identified and managed. RRSL was able to demonstrate the link between identified scenarios and the associated emergency response arrangements.
I judged that RRSL has demonstrated its on-site response capability is appropriate for protection of its assets, recovery of personnel and prevention of incident escalation. RRSL acknowledged its additional reliance on the fire & rescue provision by the local authority. However, RRSL was unable to demonstrate that it has used the full range of initiators, hazards and consequences to determine the facilities and equipment required. RRSL should seek to assure itself that no capability gaps exist, taking into account the capability of the local authority response. However, this will not require further regulatory follow up, as I consider the chance of a significant finding to be low, given the quality of the facilities and equipment observed on the day.
For the Improvement Notice Closeout inspection, I judged that RRSL provided sufficient evidence to demonstrate that the improvements made to close out the Improvement Notice adequately addressed the identified compliance gap, had undergone a robust process, featuring a stage-wise process including several senior RRSL managers and the Operations Director.
I judged that limits specified by Criticality Control Certificates (CCC) have been appropriately increased (and harmonised across element types), combined with the roll out of lower Operational Working Limits (OWL) have reduced the likelihood of future CCC breaches. Though increased, the CCC limits still leave sufficient margin to safety. Evidence of completed training on the new OWLs was seen, and this was clear through on-plant discussions with operational staff.
In my opinion, improvements made to the criticality safety surveillance routines and the lines of accountability are now well briefed and documented. On plant evidence was secured with regard to the improved surveillance routines.
Conclusion of Intervention
I judge that RRSL has adequately demonstrated capabilities against outcomes 1, 2 and 3 on the EPCRM, meeting relevant good practices. I therefore consider, noting the ONR guidance on inspection ratings, that an inspection rating of GREEN (no formal action required) is merited for the licence condition inspected. Though some opportunities for improvement exist, there were no items of significance that required a Regulatory Issue to be raised.
For the Improvement Notice Closeout inspection, based upon the sample I inspected, I judge that RRSL has made sufficient improvements against each of the Improvement Notice Schedule items to justify closure of Improvement Notice ONR-IN-20-02. Closure of the associated Regulatory Issue (8039) will be proposed.
I have chosen not to rate the inspection against Licence Condition 23 (Operating Rules) or Licence Condition 24 (Operating Instructions) given the limited and targeted scope of the inspection.