Office for Nuclear Regulation

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Licence condition compliance inspections – Control and Supervision of Operations themed intervention

Executive summary

Purpose of Intervention

This intervention, conducted at Rolls Royce Submarines Ltd (RRSL) Nuclear Fuel Production Plant (NFPP) site at Raynesway in Derby, was undertaken as part of the 2018/19 intervention plan and propulsion sub-division strategy.

Interventions Carried Out by ONR

I conducted a themed inspection on the control and supervision of operations. This inspection focused on the licensee’s implementation of arrangements for Licence Condition (LC) 23 (“Operating Rules”), LC 24 (“Operating Instructions”), LC 25 (“Operational Records”) and LC 26 (“Control and Supervision of Operations”) within a particular facility in the NFPP.

The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable.

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

No matters were identified as requiring immediate regulatory attention during the conduct of the compliance inspection.

It is my opinion that the arrangements for licence conditions 24, 25, and 26 are adequate, based on the aspects sampled for this themed inspection.

For each of the relevant LCs I sampled RRSL’s arrangements and their implementation. This included review of the discharge of operation rule information from safety case to operational instruction, understanding of the safety significance of these rules by operational staff , the recording of information required by this and the control and supervision of operations with a facility by operational staff. I made the following observations with respect to each of the LC’s:

I consider that RRSL arrangements and their implementation are adequate to demonstrate compliance with the requirements of LC 24, 25 and 26. The observations above show that there are some opportunities for improvement, but I consider that none of these are of sufficient significance to warrant further regulatory action beyond being fed back to RRSL.

I consider that RRSLs implementation of arrangements is not compliant with the requirements of LC 23 in all areas. I consider that the observations made above demonstrate shortfalls to relevant good practice but without prejudice to overall nuclear safety. I will raise a level 3 regulatory issue to seek improvement in this area.

Conclusion of Intervention

Based on my inspection of the licensee’s arrangements for compliance with LC 24, 25 and 26, I consider that RRSL have adequately implemented arrangements to ensure the safe control and supervision of operations, and a rating of Green “no formal action” for these LCs is appropriate.

Based on my inspection of the licensee’s arrangements for compliance with LC 23, I have identified areas of compliance where shortfalls exist against relevant good practice and a rating of Amber “seek improvement” is appropriate for this LC. Therefore I will raise a level 3 regulatory issue to seek improvement in this area. This improvement work will be monitored through routine regulatory business.