Office for Nuclear Regulation

Roll Royce Submarines Limited compliance inspection

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 remote Licence Condition (LC) compliance inspection was carried out of the licensee’s compliance arrangements in August 2020. 

The purpose of this inspection was for the ONR to determine the adequacy of the licensee’s formal arrangements for compliance with Licence Condition 4 (restrictions on nuclear matter on site) and Licence Condition 5 (consignment of nuclear matter).

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 formal 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 associated with the licensee’s LC 4 compliance arrangements to confirm that RRSL has established adequate arrangements to ensure that no nuclear matter is brought onto the nuclear fuel production plant (NFPP) licenced site, and stored on this site, except in accordance with these arrangements. Specifically, I concentrated on testing RRSL’s arrangements on the NFPP site since this is focused on the production of J core for the Dreadnought class of submarine. I judged that, on the evidence sampled, the licensee has adequately established and implemented arrangements for the import and storage of nuclear matter on this licenced site.

During my inspection I identified one minor shortfall and have raised a level 4 regulatory issue to ensure the mitigation of this shortfall in a timely manner.

I consider that, for licence condition 4, relevant good practice was generally met. However, one minor shortfall was identified, when compared with appropriate benchmarks. Therefore, it is my opinion that, on balance, against compliance with Licence Condition 4, an inspection rating of Green (no formal action) is merited.

During my inspection, I sampled evidence associated with the licensee’s LC5 compliance arrangements to ensure that RRSL can consign nuclear matter to a relevant site, and that the records of such actions are recorded, and preserved, for 30 years. Specifically, I concentrated on testing RRSL’s arrangements on the NFPP site since this is focused on the consignment of J core for the Dreadnought class of submarine to the relevant site at Barrow in Furnace. I judged that, on the evidence sampled, the licensee has adequately established and implemented arrangements for the consignment of nuclear matter to a relevant site. Further, the records and current record retention methodology of such consignments meets relevant good practice as defined in ONR’s LC5 guidance.

During my inspection I identified one minor shortfall and have raised a level 4 regulatory issue to ensure the mitigation of this shortfall in a timely manner.

I consider that, for licence condition 5, relevant good practice was generally met. However, one minor shortfall was identified, when compared with appropriate benchmarks. Therefore, it is my opinion that, on balance, against compliance with Licence Condition 5, an inspection rating of Green (no formal action) is merited.

Conclusion of Intervention

From the evidence sampled during these inspections, I judge that the LC4 and LC5 arrangements are adequate. RRSL need to ensure their written instructions include all instructions necessary in the interests of safety to improve the robustness of their arrangements and to ensure their record management arrangements enable them to keep up with changes in information technology.

ONR has raised 2 level 4 regulatory issues to ensure that the two minor shortfalls identified, will be addressed in a timely manner.