- Site: RRSL
- IR number: 21-103
- Date: October 2021
- LC numbers: 7
Executive summary
Purpose of Intervention
The purpose of this intervention was to evaluate the adequacy of Rolls-Royce Submarines Limited’s (RRSL) arrangements for Licence Condition (LC) 7 (‘Incidents on the site’) at the Raynesway nuclear licensed sites.
Also captured in this record are other ONR-RRSL engagements performed whilst ONR was on site.
Interventions Carried Out by ONR
The LC7 intervention was conducted on site by the ONR nominated site inspector, utilising relevant good practice from ONR-INSP-GD-007 revision 6.
Other engagements included discussions with selected safety representatives and a discussion on the scenario for the upcoming level 1 emergency arrangements demonstration exercise. These engagements were not rated.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
I consider that RRSL now has clear objectives for the improvement of the LC7 process. These objectives are clearly reflected in the improvement plan for LC7 which is resource-backed and supported by the Head of Safety. I found that improvements have been made in the working level arrangements and these now reflect relevant good practice. However, further evidence needs to be gained to ensure that implementation of the revised arrangements will result in a process that is both effective and efficient.
I noted some implementation shortfalls still exist which can be traced back to previous inspections (principally robust and timely action and investigation closure), however I consider that the revised arrangements introduce, clarify and/or strengthen expectations in these areas. Roll-out and associated training/briefing of the revised arrangements will need to be managed to ensure an effective implementation.
Conclusion of Intervention
Based on the sample inspected, I rate the LC7 inspection as GREEN – ‘No Formal Action’. This rating is in line with the established ONR guidance:
- “Relevant good practice generally met, or minor shortfalls identified, when compared with appropriate benchmarks.”
- “No significant shortfalls identified in the delivery of safety, safeguards or security functions.”
The level 3 regulatory issue (8119) will be proposed for closure on the basis of the revised arrangements having been issued and the quality of investigations having improved. A new level 4 regulatory issue will be raised to track the improvement plan through to a suitable conclusion. RRSL should be cognisant of the AMBER inspection history – ONR expects forward progress to be maintained.
Annual LC7 compliance inspections will continue at RRSL, with the next inspection planned for May 2021 to tie in with the improvement plan delivery schedule.