This intervention was conducted at Rolls-Royce Submarine Limited’s (RRSL) Neptune Nuclear Licenced Site (NNLS) and Nuclear Fuel Production Plant (NFPP) licensed sites. It focused on the adequacy of their arrangements for compliance with Licence Condition 35 (decommissioning) as part of the 2018/19 integrated intervention strategy (IIS).
The Licence Condition 35 (decommissioning) compliance inspection focused on the licensee’s decommissioning strategy, decommissioning plan and their consideration of decommissioning within initial design work. The intervention aligns with the obligation placed on the Office for Nuclear Regulation to conduct a Quinquennial Review of the licensee’s decommissioning strategy “to ensure that operators' decommissioning strategies remain soundly based as circumstances change” (White Paper Cm2919).
The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.
No matters were identified as requiring immediate regulatory attention during the conduct of the compliance inspection.
I concluded that RRSL’s decommissioning strategy (4 years and 8 months old at the time of the inspection) did not align with the pace of their regeneration plans and work being undertaken across both licenced sites. This was also the case for the facility decommissioning plans (5 years and 7 months old at the time of the inspection). Their LC 35 compliance arrangements instructed the licensee to review these on a 5 year cycle therefore the licensee has not followed their own arrangements for the decommissioning plan.
Based upon the evidence sampled, I judge that the regulatory expectation to consider decommissioning during the initial design phase of a project was met within the Rolls-Royce corporate arrangements and engineering process lifecycle map.
On the basis of the evidence sampled, in line with ONR inspection rating guidance, it is my judgement that the licensee does not have an up to date decommissioning strategy or plan which reflects the regeneration works being undertaken across the licenced sites. The LC 35 compliance arrangements state the 5 year periodicity requirement for the review in order to maintain compliance. Therefore, at this time, I considered that as the licensee is not adequately maintaining an up to date decommissioning strategy and plan, an inspection rating of Amber (seek improvement) is merited.
A single Level 3 Regulatory Issue is raised to ensure the licensee updates both the decommissioning strategy and facility plans, and reviews the periodicity of conducting future reviews against the Raynesway estate strategy to ensure it remains current.