This intervention at the BAE Systems Marine Ltd. (BAESML) Barrow licensed site was undertaken as part of the 2016/2017 ONR planned inspection plan for the site.
The inspection examined BAESML’s arrangements made under Licence Condition (LC) 23 for Operating Rules and the implementation of these arrangements. The LC was inspected using ONR’s relevant Technical Inspection Guide.
The LC23 compliance inspection found that:
BAESML has identified safety conditions and limits (C&Ls) which are clearly defined and understandable to the plant operators.
BAESML’s process for deriving operating rules appears to be largely based on historical practice, and there is no clear linking to the analysis. Further, BAESML do not appear to have a rigorous process for classification of the C&Ls.
The C&Ls have been implemented in operating instructions and other working level procedures. The operators were aware of the requirements and intent of the safety case C&Ls.
Although not the principle subject of this inspection, the inspection highlighted several shortfalls in BAESML’s LC22 arrangements for modifications associated with construction activities on the site.
Based upon the evidence examined during this inspection, we consider that BAESMLs LC23 arrangements are adequate, since the existing conditions and limits seem appropriate for controlling nuclear safety, and they have been adequately implemented in the working level documentation. However, a number of shortfalls related to the derivation and classification of C&Ls have been identified, which has resulted in the modification and strengthening of the relevant existing regulatory issues.