This was a planned intervention at BAE Systems Marine Limited’s (BAESML’s) Devonshire Dock Complex (DDC) nuclear licensed site at Barrow, undertaken as part of the intervention strategy for the DDC site for 2015/16.
I inspected Licence Condition 36 (LC36) “organisational capability”. This condition relates to maintaining adequate financial and human resources to ensure safe operation and controlling any changes to organisational structure or resources. During this inspection I focussed on those aspects of changes to organisational structure, for two reasons, firstly, because BAESML will soon implement, via several stages, changes to its submarine build organisation. Therefore, focus on those parts of LC36 arrangements is timely. Secondly, because new arrangements relating to adequate resources (including establishing a new nuclear baseline) will soon be implemented by BAESML. Focus on the current nuclear baseline arrangements would therefore be of limited value. I also took into account that LC36 is part of Phase 2 of BAESML’s Licence Condition Compliance Improvement (LCCI) programme.
In relation to LC36 I noted that improvements to compliance arrangements would soon be made as part of BAESML’s continuing improvement programme initiated in response to ONR serving an Improvement Notice relating to Licence Condition 12 “duly authorised and other suitably qualified and experienced persons” in December 2014. In relation to those aspects of LC36 dealing with changes to organisational structure I concluded that the BAESML arrangements for compliance did not refer to the current position in the BAESML management system (e.g. it referred to documents that had been replaced and to roles responsible for compliance that had changed). I also concluded that classification of changes to organisational structure according to safety significance was not uniquely defined and referenced in BAESML’s arrangements for compliance. I concluded that guidance on when to use a management of organisational change control form needed clarification to ensure consistency. In terms of implementation I identified issues relating to ensuring sign-off of change proposal forms before start of implementation of the change and issues relating to the process in place to deal with organisational changes that are not implemented at all or are not implemented in full. I raised a single ONR compliance issue to cover all these findings. I have requested that this issue is completed before BAESML implements the second stage of its build organisation change. Taking these factors into account I judged the arrangements inspected under LC36 to be below standard.
In relation to the review of the ONR issues database with BAESML, I consider that adequate progress is being made overall by BAESML.
In relation to the discussion of the first stage of BAESML’s build organisation change, I made suggestions which have been incorporated into the draft proposal. I have also requested that BAESML’s LC36 arrangements are modified to allow flexible permissioning through enhanced implementation monitoring and control and referred Site to the ONR Guide “Flexible Permissioning Including the Use of Derived Powers”.
In relation to the other activities undertaken in this intervention, no key findings arose.
From the evidence gathered during this intervention, no matters have been identified that are likely to have a significant impact on nuclear safety on the site at this time. Therefore, no further regulatory action arising from this visit is considered necessary.