Office for Nuclear Regulation

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Compliance inspection of Licence Condition 22 (modification on plant)

Executive summary

Purpose of Intervention

The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Nuclear Fuel Production Plant site licensee (Rolls Royce Submarines Limited (RRSL)) against a strategy defined by the ONR propulsion sites sub-division. In accordance with that strategy, a Licence Condition (LC) compliance inspection was carried out in the clean shop in June 2019. 

The purpose of this inspection was for ONR to determine the adequacy of implementation of the licensee’s arrangements for compliance with LC 22 (modification or experiment on existing plant).

Interventions Carried Out by ONR

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

I used ONR guidance documentation NS-INSP-GD-022, Revision 4, issued in January 2018 for this intervention.

Explanation of Judgement if Safety System Not Judged to be Adequate

This was not a system based inspection, and therefore no judgement has been made of the adequacy of implementation of any part of the safety case.

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

During my inspection, I sampled evidence associated with the licensee’s compliance with its arrangements for the modification of plant systems and/or processes that affect safety.  Specifically, I concentrated on the categorisation of significant modifications on plant, the qualification and experience of the staff, and the adequacy of implementation of a number of recent modifications.  .

The licensee identified several shortfalls in their LC 22 arrangements on the day of the inspection. I judged that the licensee should implement a suitable and sufficient improvement plan to mitigate these shortfalls as well as those I identified.

I judged the qualification and experience of the staff involved with the categorisation and implementation of modifications on plant to be comprehensive and in lne with relevant good practice.

During my inspection I found shortfalls against relevant good practice, such as the absence of the source and method change process from their LC22 arrangements.  Therefore an inspection rating of Amber (seek improvement) is merited.

Conclusion of Intervention

From the evidence sampled during these inspections, overall I judge that the LC22 arrangements require improvement.   

ONR will undertake a follow-up regulatory engagement to inspect implementation of the RRSL LC 22 improvement programme, and to review progress with closure of the associated level 3 regulatory issue.