Office for Nuclear Regulation

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BAE Systems Marine Limited (BAESML) - Devonshire Dock Complex - Planned Intervention

Executive summary

Purpose of intervention

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.

Interventions Carried Out by ONR

A team of ONR inspectors inspected arrangements made under Licence Condition 12 (LC12) “duly authorised and other suitably qualified and experienced persons” jointly with the Defence Nuclear Safety Regulator (DNSR) on 25 February 2016.  The ONR purposes of this inspection were to:

  1. Undertake a planned compliance inspection of LC12, focussing on LC12(1)1.
  2. Assess the progress that BAESML has made regarding compliance with an Improvement Notice served by an ONR inspector regarding contraventions against LC12.  This Improvement Notice (IN) was served on 3 December 2014. The compliance date for this Notice is 31 March 2016.  The wording of the Notice reflects the requirements of LC12(1), which is why the planned compliance inspection focussed on this clause of the LC.
  3. Identify any final additional information needed for the outgoing ONR nominated site inspector (nuclear safety), who is responsible for monitoring BAESML’s progress relating to the IN, to be of the opinion that the notice has been complied with2.

In addition, ONR attended the annual Level 1 Regulatory Interface Forum (RIF) where senior regulators meet with BESML Managing Director and other senior BAESML staff, representatives of the Ministry of Defence, DNSR and the Environment Agency also attended.  At the Level 1 RIF matters of strategic importance relating to the licensed site and UK regulation were discussed and outstanding issues resolved, as necessary.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable.

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

In relation to the planned compliance inspection of LC12, focussing on LC12(1), we observed commitment at all levels of the organisation to evolve and further embed the LC12(1) arrangements into systems that will both meet regulatory expectations and deliver significant benefit to BAESML.  From the evidence sampled, we judge that BAESML’s arrangements to comply with the requirements of LC12(1) are adequate.  We acknowledge that BAESML is implementing new arrangements in this area and a number of shortfalls, as well as areas of good practice, were observed warranting an overall rating of adequate for LC12.

In relation to compliance with the LC12 IN considerable progress towards compliance was demonstrated and I the ONR nominated site inspector (nuclear safety) am of the opinion that adequate LC12(1) arrangements have been made.  I am also of the opinion that substantial progress has been made with implementing these arrangements and that only authorised nuclear capability plans now remain to be provided before I am of the opinion that the arrangements have been adequately implemented.  Once these plans have been received and reviewed I will write to BAESML confirming that in my opinion the IN has been complied with.

In relation to the Level 1 RIF, the meeting was presented with an overview of current and future challenges for the site and it dealt openly with safety issues.  The most significant matter under discussion was the extent of relicensing at the Barrow site to accommodate Successor related activities.  A strategic way forward was agreed, which will be worked through carefully between all interested parties at subsequent lower level meetings.

Conclusion of Intervention

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.


  1. LC12(1) states that “The licensee shall make and implement adequate arrangements to ensure that only suitably qualified and experienced persons perform any duties which may affect the safety of operations on the site or any other duties assigned by or under these conditions or any arrangements required under these conditions”.
  2. In judging progress with the IN and identifying any final additional information needs, the outgoing ONR nominated site inspector (nuclear safety) has taken on board the views of the ONR Human Factors specialist inspector and the ONR inspector.