Office for Nuclear Regulation

RRMPOL, Nuclear Fuel Production Plant and Neptune Reactor Licensed Sites Raynesway LC 7 Compliance Inspection

Executive summary

Purpose of intervention

This inspection was undertaken at the RRMPOL Nuclear Fuel Production Plant and Neptune Reactor Licensed Sites in accordance with the inspection plan for 2015/16.  The purpose of the inspection was to judge the extent to which the Licensee complies with Licence Condition (LC) 7, which relates to incidents on the site.

Interventions Carried Out by ONR

An ONR Human Factors Specialist Inspector and the ONR Nominated Site Inspector undertook an LC 7 inspection of the two RRMPOL licensed sites.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable during this intervention.

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

It is the ONR inspectors’ judgement that the Licensee’s compliance with LC7 is adequate overall, with some areas for improvement identified during the inspection.

It was noted that the Licensee has invested significant effort and resource to tackle matters identified during the previous ONR LC7 inspection (January 2014) and that the Licensee now has a suite of arrangements that are compliant with ONR expectations for LC7.

The level of resource available to the RRMPOL Health Safety & Environment Team has increased significantly allowing the Licensee to implement the proposals it made in response to the January 2014 inspection.  We were satisfied that these proposals have been implemented however, it is clear that they are not fully mature and we welcome the Licensee’s commitments to make further improvements.

The Licensee accepts that it can make further improvements to meet some aspects of other regulatory requirements (e.g. Management of Health and Safety at Work Regulations) and will write to ONR committing to do this. 

Whilst weaknesses were observed in the Licensee’s auditable trail, the Licensee was able to demonstrate progress towards closure of identified actions for all the events examined during this inspection.  Giving that there was no observed shortfall in the Licensee’s response to events or their subsequent investigation, we deemed the arrangements and their implementation to be adequate.

Two inspection findings were identified.

The Licensee should ensure a greater focus is maintained on events that have potentially significant nuclear / process safety impact and ensure that root causes are identified and highlighted to help prevent recurrence.

The Licensee should ensure that an appropriate auditable trail is maintained to ensure the robustness and transparency of the Licensee’s processes for sentencing, investigation, shortfall identification and closure of remedial actions is maintained.

In addition, a number of observations were highlighted to the Licensee to enable them to further improve their learning from experience activities.

Conclusion of Intervention

The ONR inspectors’ judged the Licensee’s compliance with LC7 to be adequate overall.  This was communicated to the Licensee at the end of the inspection along with findings and observations that the Licensee should consider to further enhance their arrangements in this area.