Office for Nuclear Regulation

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Licence Condition 13: Nuclear Safety Committee, compliance inspection

Executive summary

Purpose of intervention

This intervention at the Rolls Royce Marine Power Operations Ltd (RRMPOL) licensed sites at Raynesway, Derby was undertaken as part of a planned series of inspections during 2015/16.  The purpose of this inspection was to judge the extent to which the licensee complies with Licence Condition (LC) 13, which requires the licensee to have a Nuclear Safety Committee to provide it with advice.

Interventions Carried Out by ONR

On the 09-10 September 2015 the ONR Defence Programme (Propulsion) Leadership and Management for Safety Specialist Inspector and the Nominated Site Inspector, undertook a LC13 inspection of the two RRMPOL licensed sites.

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A

Key Findings, Inspector's Opinions and Reasons for Judgements Made

It is the ONR inspectors’ judgement that the licensee’s compliance with LC13 is adequate overall, with some areas for improvement identified during the inspection.  These include:

The terms of reference refer to the NSC’s role in the ‘endorsement’ of submissions, under a section headed ‘Approval of Submissions’.  It is ONR’s expectation that the NSC should not be required to ‘agree’, ‘endorse’ or ‘approve’ any matters put to it since that might undermine its purely advisory role.

The NSC does not have a mature schedule of matters that the licensee intends to submit to the NSC for consideration and advice.

From reviewing the NSC minutes and also from observing an NSC meeting, it was at times unclear what constitutes the formal advice of the NSC to the licensee.

It was noted that the current membership, taken as a whole, would benefit from review to ensure that it is appropriate for the lifecycle phase of the installation(s). 

We note that the licensee had conducted its own internal review and had identified similar areas for improvement. The NSC Chairman shared his plans to address the findings to improve the effectiveness of the NSC, and ONR’s inspectors were satisfied that these plans would address our findings. ONR’s inspectors note two features of the NSC that they judged to contribute significantly to its success.

Detailed examinations of specific topics outside of a formally constituted meeting to enable the NSC members to be able to provide higher quality advice on the topic in question at a later NSC meeting.

Good attendance by a relatively high number of independent members (often five or more per meeting).

Conclusion of Intervention

The ONR inspectors’ judged the licensee’s compliance with LC13 to be adequate overall.  This was communicated to the NSC Chairman at the end of the inspection along with observations that the licensee may want to consider to further enhance the administration and effectiveness of the NSC.  The findings and observations will be followed up during routine interventions with RRMPOL leadership.