Date(s) of inspection:
- January 2023
Aim of inspection
This was a planned intervention to evaluate the adequacy of Rolls-Royce Submarines Limited’s (RRSL) arrangements, and implementation thereof, for licence conditions 6 (documents, records, authorities and certificates) and 25 (operational records) at the Raynesway nuclear licensed sites. The inspection was conducted in parallel to an existing planned inspection in order to reduce the overall burden on the licensee whilst maximising the value of the inspection activities.
The LC6 and LC25 aspects of the intervention were conducted on-site by the ONR nominated site inspector for the Raynesway nuclear licensed sites, utilising relevant good practice from ONR-INSP-GD-006 revision 5 and ONR-INSP-GD-025 revision 7.
Subject(s) of inspection
- LC 06 – Documents, records, authorities and certificates – rating: Green
- LC 25 – Operational records – rating: Green
Key findings, inspector’s opinions and reasons for judgement made
From the sample undertaken during this inspection, I found that RRSL has a competent Information Management team and adequately creates and stores records relating to radioactive waste operations and other nuclear safety activities, in addition to being able to successfully retrieve historic records from both on and off-site facilities. The focus of the LC6 inspection on the storage and retrieval of records has resulted in RRSL undertaking a review of its activities in this area and identifying several LC6-based improvement areas (including, amongst others; digitisation of historic records, emptying temporary archives reviewing Intelligent Customer accountabilities and generation of an RRSL-wide integrated assurance plan), for which underpinned programmes need to be generated. The improvement areas aligned with my findings during the intervention, and whilst I consider them necessary to address, they do not pose a direct threat to nuclear safety at the site. I have raised a level 4 regulatory issue to track the generation and implementation of an integrated improvement plan.
Based on the sample inspected, I rate both the LC6 and LC25 interventions as GREEN – ‘No Formal Action’. This rating is in line with the established ONR guidance.
- “Relevant good practice generally met, or minor shortfalls identified, when compared with appropriate benchmarks.”
- “No significant shortfalls identified in the delivery of safety, safeguards or security functions.”
I have raised regulatory issue RI-11262 to track the creation and implementation of an integrated improvement plan for the LC6 improvement areas.