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 2 “Marking of the site boundary” and LC 26 “Control and Supervision of Operations”.
The purpose of Licence Condition 2 (LC2) is to ensure that the extent of the licensed site boundary is marked and the public is protected from danger by preventing inadvertent or unauthorised entry. In addition marking helps to ensure everybody knows whether they are on or off the licensed site so that they can take the correct actions in the event of an emergency. The boundary, which should be identifiable by both the public and employees, usually consists of a fence and warning notices. The main purpose of fencing the boundary is to allow the licensee to control entry if it needs to apply different conditions to the entry of different classes of person e.g. members of the public and workers.
The purpose of Licence Condition 26 (LC26) is to ensure that all safety related operations are only carried out under the control and supervision of suitably qualified and experienced personnel. The “operations ......... which may affect safety” to which condition 26 applies clearly includes those referred to in condition 23 for which safety cases are required to be produced but, importantly, is more widely drawn to include all “operations” as defined in LC1.
The Suitably Qualified and Experienced Persons (SQEPs) required to control and supervise all such operations will be identified and appointed. For the control and supervision of operations in appropriate cases (generally those that are most safety significant), Duly Authorised Persons may be appointed under condition 12(2).
The LC2 and 26 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 2 have been effectively implemented on the Barrow site. The licensee has adequate arrangements to ensure that the extent of the licensed site boundary is marked and the public is protected from danger by preventing inadvertent or unauthorised entry. Some observations were recorded and have been provided to the Defence Nuclear Safety Regulator.
It is recognised that improvements are being implemented and tracked by ONR I consider that BAESML’s arrangements for compliance with LC 26 are adequate at the operational level, however prompt implementation of the improvements would ensure that the hierarchy of control and supervision would further enhance and support site operations. The inspection involved personnel at all levels of the organisation who consistently provided the same message of reassurance that the organisation was committed to change the culture of control and supervision in line with industry best practise and ONR’s expectations.
I consider implementation of the site’s arrangements for LC2 and LC26 as adequate. I will continue to monitor progress against the extant Regulatory Issue related to LC26.