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 2016/17. I undertook a planned inspection of LC 16 "Site plans, designs and specifications" and LC 22 "Modification or experiment on existing plant".
The purpose of Licence Condition 16 (LC16) is to require information to augment Schedule 1 to the Site Licence, through the provision of a detailed site plan and schedule of all buildings, plant areas and associated operations which might affect safety. The buildings and plant included in the plan and schedule should be identified on the basis of safety significance and should both be subject to procedures ensuring they are kept up to date.
The purpose of Licence Condition 22 (LC22) is to ensure that there are arrangements to categorise and control all modifications and experiments on existing plant or processes that have the potential to affect safety directly. The arrangements should cover all stages of the modification or experiment, from its initial proposal through to ensuring, prior to commissioning, that adequate preparations are made for its execution and the update of all relevant documents, including plant drawings and safety documentation, operating rules, operating instructions and the maintenance schedule. The modification or experiment may require personnel to undergo elements of additional training before the commencement of commissioning and operations, and to demonstrate that staff satisfy the requirement to be SQEP and/or DAP where this is appropriate.
The LC16 and 22 inspection comprised of discussions with BAESML staff and examination of documentation and records focussed on the following areas:
I consider that BAESML's arrangements for compliance with LC 16 have been effectively implemented on the Barrow site. The licensee has adequate arrangements in place for the provision of a detailed site plan and schedule of all buildings, plant areas and associated operations which might affect safety.
I consider that BAESML's arrangements for compliance with LC 22 are below standard. The inspection identified some shortfalls in aspects of the arrangements. The Nuclear Safety Documentation Committee (NSDC) and Site Design Change Committee (SDCC) consider changes on the site and the route for a modification can switch from the SDCC to the NDRC depending on the content of the proposal thus their differing perspectives suggests that a potential exists where the totality of the modification is not considered. The current arrangements make no provision for changes to the extant safety case, there is no provision to demonstrate that wider considerations of risk associated with modification if it is poorly conceived and/or inadequately implemented. The guidance to consider wider risks is at a very high a level and may not prompt significant debate or challenge, or for a more detailed consideration of the wider risks associated with a modification, nor significant challenge from the approving committees. There is evidence of inconsistent classification of modifications. There is evidence of insufficient configuration control. This view was accepted by the licensee.
I consider implementation of the site's arrangements for LC16 as adequate and I have rated BAESMLs as green.
I consider the site's arrangements for LC22 to be below standard and I have rated BAESMLs as amber. I have raised a regulatory issue to track the improvements.