The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Nuclear Fuel Production Plant (NFPP) site licensee, Rolls Royce Submarines Limited (RRSL), against a strategy defined by the ONR Operating Facilities Division and Defence (Propulsion) Sub-Division. In accordance with that Strategy, a Licence Condition compliance inspection of the Core Design and Manufacture (CDM) business unit was carried out as identified within the planned inspection schedule for NFPP/RRSL.
This planned intervention was undertaken to determine if the Contact Shop facility/CDM is adequately implementing RRSL’s arrangements for compliance with Licence Condition 7 (LC7) – Incidents on the Site. The Contact Shop facility was initially chosen because of the radiological hazard associated with fuel manufacture and the risk of contaminated wounds due to operations undertaken there. The inspection scope was expanded to include the Chemical Plant as a result of an event prior to the inspection.
LC7 requires RRSL to make and implement adequate arrangements for the notification, recording, investigation and reporting of such incidents occurring on the site. The findings from previous LC7 inspections were taken into consideration when planning this inspection (CM references: 2015/449405 and 2014/58387).
I carried out a one-day, on-site, licence condition compliance inspection of the Contact Shop and Chemical Plant against the requirements of LC7, accompanied by the ONR nominated site inspector.
The inspection was comprised of a discussion with RRSL staff and an examination of a sample of Contact Shop / Chemical Plant facility documentation to determine if RRSL’s LC7 arrangements have been adequately implemented. The inspection was carried out in accordance with the following formal ONR inspection and assessment guidance:
'LC7 Incidents on the Site, NS-INSP-GD-007, Revision 4, July 2017 and,
‘ONR Inspection Rating Guide’ (2016/118606).
N/A; this was not a System Based Inspection (SBI).
ONR observed a number of good practices associated with the implementation of RRSL’s compliance arrangements. These were:
Notwithstanding the good observations, on balance, from the evidence sampled during this inspection, I judge that RRSL has significant shortfalls in its arrangements for the evaluation and screening of incidents, investigation process, trending and training.
The RRSL LC7 compliance arrangements do not meet relevant good practice, as described in TIG-007, nor reflect RRSL’s actual way of working.
Although RRSL operates in accordance with relevant good practice it does not comply with its own arrangements which are incomplete and inadequate. I have therefore assigned an inspection rating of AMBER (Seek Improvement).
No matters were identified as requiring immediate regulatory attention during the conduct of the compliance inspection.
The inspection findings were shared with, and accepted by, RRSL as part of routine inspection feedback. I have raised one Level 3 Regulatory Issue, as a result of this inspection to ensure the identified shortfalls are effectively remedied promptly.