Office for Nuclear Regulation

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Barrow – LC26 and LC36 Compliance inspections

Executive summary

Purpose of Intervention

This intervention examined how BAE supervises activities important to nuclear safety, examining the management expectations for supervision, how well these were understood and implemented and their effectiveness in the workplace.

The intervention also looked at progress in implementing a recent organisational change, specifically looking at how licence condition sponsorship and ownership changes were being tracked. It included sampling the recorded roles and responsibilities for supervision on the developing new staff roles (baseline) tracking tool.

Interventions Carried Out by ONR

The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.

This intervention was carried out through a series of structured discussions with the sponsors and owners of licence condition 26, the internal regulator, key personnel identified as supervisors, those being supervised, and the lead TU safety representatives on site.   The inspection also witnessed setting to work of site maintenance and submarine commissioning work, and direct observation of supervisors in the workplace. 

Discussions were with those tracking the implementation of the organisational change involving live inspection of elements of the BAE management system relating to personnel and role profiles.

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A

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

Clear evidence of control of work processes being well defined and well implemented was demonstrated, with clear roles and responsibilities identified for control.  However, when inspecting the supervision arrangements and their implementation specifically, I found that roles and responsibilities, and expectations for the quantity, quality and focus of supervision were implicit rather than explicit in the arrangements.   It was evident that BAE Management and internal assurance were aware of this area for improvement, and were developing actions to address the shortfall against an existing regulatory issue.  I judged that whilst the improvement plan was starting to deliver, and that individuals were aiming to supervise key operations based on their professional judgement and experience, there is still room for improvement on clarity of expectations and guidance on how to achieve it. 

An extant finding from a previous intervention (being tracked as a regulatory issue) remains open:

The due date was revised to 31/06/19 to reflect the delivery of the current improvement plan. Delivery will be actively tracked through the routine regulatory interventions as outlined in the Integrated Intervention Plan for the site.

Three observations were raised that will support closure of the open regulatory issue:

The organisational change to a matrix management organisation was judged to be being implemented effectively. The BAE team had good oversight of the process, status of the change and could assure us that changes to roles and responsibilities involving supervision were being tracked effectively, therefore no findings or observations were raised against LC 36.

Conclusion of Intervention

Implementation of arrangements for the control of work important to nuclear safety was judged as adequate.  However, there were improvements required to those arrangements and their implementation in terms of expectations and requirements for supervision.  These expectations were implicit rather than explicit, and hence not clearly and consistently understood and implemented by those identified as supervisors by the company.   BAE were aware of the issue, and their internal assurance function and our workplace observations provided confidence that a level of supervision for ensuring nuclear safety was present.  However, I judged that some improvement is necessary to meet relevant good practice and the extant regulatory issue remains open.    I judged that compliance with LC 26 was AMBER – some improvement required.

The implementation of the major organisational change is under effective management and oversight, and I therefore judged compliance with LC 36 as GREEN.