The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with Rolls Royce Submarines Limited (RRSL) against a strategy defined by the ONR Propulsion Division. This intervention relates to Licence Condition 17 (LC17), which requires a Licensee to make and implement a management system that gives due priority to safety. A fundamental element of these arrangements is the Licensee’s Supply Chain Management (SCM) arrangements.
In accordance with the strategy and the requirements of LC17, a supply chain inspection was carried out between 1st and the 18th March 2021.
The purpose of this inspection was to gain confidence in Rolls Royce Submarines Limited (RRSL) arrangements for supply chain management (SCM) and procurement activities for nuclear safety related items or services.
Due to the limitations currently in place as a result of the Coronavirus (COVID-19) pandemic, it was decided to undertake this inspection remotely via a series of modules undertaken over several weeks.
The inspection determined the adequacy of Rolls Royce supply chain management arrangements and its implementation against ONR’s regulatory expectations, informed by relevant good practice and ONR guidance documentation. Regulatory expectations for supply chain management arrangements and procurement activities for nuclear safety related items or services are in NS-TAST-GD-077: Procurement of Nuclear Safety Related Items or Services (TAG 077).
The implementation of those arrangements was reviewed using two sampled projects: the de-planting and regeneration of the Neptune testing facility (described as the ‘Neptune’ project) and the construction of a new Product Assembly Building (PAB).
This inspection was rated based on the ONR inspection rating system guidance as explained ONR-INSP-GD – 064 - ONR ‘Compliance Inspection Guide’. This is available on the ONR external website.
During the inspection, I identified several shortfalls that presented increased potential risks to RRSL’s supply chain management arrangements. These short falls were as follows:
Based on the evidence sampled, I have concluded that RRSL’s SCM arrangements were not adequate when compared to relevant good practice and the requirements of TAG-077. This could contribute to an increased risk when procuring nuclear safety related items or services.
As such, I concluded that an ONR inspection rating of AMBER (seek improvement) was appropriate.
I will monitor the RRSL improvement activities to address these shortfalls by raising a: