Office for Nuclear Regulation

Compliance Inspection of LC19 – Construction or installation of new plant

Executive summary

Purpose of Intervention

This intervention, conducted remotely by ONR and the Licensee’s Rolls-Royce Submarines Ltd. (RRSL) staff, was undertaken as part of the 2020/2021 intervention plan and propulsion sub-division strategy.

Interventions Carried Out by ONR

ONR conducted a licence condition (LC) 19 “Construction or installation of new plant” compliance inspection, focused on the adequacy and implementation of the Licensee’s arrangements, to control the proposed future construction of new facilities.

LC’s are inspected against the Office for Nuclear Regulation (ONR’s) Technical Inspection Guides (TIG) and rated in accordance with ONR’s Inspection Rating Guide.  Further information can be found on the ONR website.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable.

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

No matters were identified as requiring immediate regulatory attention during the conduct of this compliance inspection.

The Licensee self-identified significant shortfalls in its LC19 arrangements, which were consistent with the findings of the ONR inspection team, based on their pre-inspection sampling.  These shortfalls were largely attributable to the existing arrangements having been written to support the projects of the initial phase of infrastructure refurbishment at the Raynesway site, which did not include the proposed second phase programme.  In addition, the following shortfalls were identified and are to be addressed by the Licensee updating and implementing its LC19 arrangements:

Based on the evidence presented, I am of the opinion that the Licensee’s existing arrangements are inadequate to control its proposed future construction activities, which may affect safety. 

A minor shortfall against relevant good practice was identified in relation to key roles with responsibilities and accountabilities relating to safety and oversight not being filled or fully defined, which if not done so in a timely manner, may impact safety.

Conclusion of Intervention

Based on the evidence sampled, I judged that the Licensee’s arrangements for LC19 are inadequate to control the proposed future construction programme, which, as a result, may affect safety.  A Level 3 Regulatory Issue will be raised on ONR’s Regulatory Issues database to ensure that the Licensee addresses the shortfalls identified, in a timely manner.