Office for Nuclear Regulation

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RRSL - Compliance inspection of Licence Condition 14

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 propulsion sites sub-division. In accordance with that strategy, a Licence Condition (LC) compliance inspection was carried out on the Nuclear Fuel Production Plant (NFPP) site in January 2020. 

The purpose of this inspection was for the ONR to determine the adequacy of the implementation of the licensee’s formal arrangements for compliance with LC 14 (safety documentation).

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.

As part of my preparation for the delivery of this intervention, the following ONR guidance documentation was used:

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 of the licensee’s compliance with its formal arrangements for producing and maintaining safety cases at their facilities. To do this I sampled the Clean Shop safety case, inspected the live versions of the safety documentation for this facility (safety case and working documentation) and sampled evidence of previous modifications to this safety documentation. I judged that, on the evidence sampled, the licensee has adequately implemented their arrangements.

I did, however, identify two minor shortfalls in the implementation of the licensee’s LC 14 arrangements against relevant good practice. The licensee has agreed to implement a proportionate improvement plan to mitigate these shortfalls.

I consider that for licence condition 14, the licensee has in general complied with all legal duties; therefore it is my opinion that an inspection rating of Green (adequate) is merited.

Conclusion of Intervention

From the evidence sampled during this inspection, I judge that, for licence condition 14, the licensee has in general, complied with all legal duties, and that only two minor shortfalls were identified against relevant good practice.

Two Level 4 regulatory issues will be raised to ensure that these minor shortfalls are addressed in a timely manner.