This intervention was one of a series of planned interventions for the BAE Systems Marine Limited (BAESML’s) licensed nuclear site at Barrow, in line with the strategy for regulating the site during 2015/16. I undertook a planned inspection of LC 6 “Documents, records, authorities and certificates” and LC 28 “Examination, Inspection, Maintenance and Testing (EIM&T)”.
The purpose of Licence Condition 6 (LC6) is to ensure BAESML makes and holds adequate records for a suitable period to demonstrate historical compliance with licence conditions. Specific requirements include the currency, the availability and accessibility of the records.
The purpose of Licence Condition 28 (LC28) is to ensure that the Licensee make and implement adequate arrangements for the regular and systematic Examination, Inspection, Maintenance and Testing (EIM&T) of all plant that may affect safety.
My inspection, which comprised discussions with BAESML staff and examination of the Plant Maintenance System (PMS), documentation and training records focussed on the following areas:
I consider that BAESML’s arrangements for compliance with LC 6 have not been effectively implemented on the site as records of significance were not identified in the management system and records were not being retained in the approved repository. This was accepted by the licensee. I have added actions to the existing regulatory issue to track this improvement.
I consider that BAESML’s arrangements for compliance with LC 28 have not been effectively implemented on the Barrow site. The lack of an integrated management system has led to both the arrangements and the implementation of the arrangements being incomplete and unclear. Multiple local repositories for data have led to significant difficulties in providing evidence during the inspection. There is no process for the formal appointment of SQEP Supervisors and physical evidence is not retained of any completed maintenance. This was accepted by the licensee and I have raised a regulatory issue to track this improvement.
I consider implementation of the site’s arrangements for LC6 and L28 to be below standard. I have raised/amended regulatory issues to track the improvements.