The purpose of this intervention was to undertake a planned inspection at BAESML, Barrow, in accordance with ONR’s Intervention Plan for the regulation of BAESML 2019/20.
ONR undertook an intervention to examine BAESML’s application of the Management of Change (MOC) process to the Primary Build Organisation (PBO) organisational change proposal, including an LC36 (Organisational Capability) compliance rating.
N/A – this was not a Safety System inspection.
On the basis of the areas sampled during the intervention, I judged that BAESML had adequately applied their LC36 arrangements in the production and governance of the PBO MoC proposal and that Relevant Good Practice (RGP) had been applied by the licensee in a number of areas. There were no major shortfalls identified. The licensee’s categorisation of the overall PBO MoC harmonised with the criteria within their arrangements and was judged to be reasonable with respect to assessed nuclear safety impact.
Areas of good practice with respect to the PBO MoC proposal identified during the intervention were: risk assessments, status of the Change Register, organisational change learning (internal) and application of a phased approach for implementation with an associated gate review process.
Regulatory observations (areas for improvement) and recommendations with respect to the PBO MoC proposal identified during the intervention were:
With respect to permissioning strategy, I noted that ONR will take the BAESML PBO MoC proposal for information only and that Enhanced Implementation Monitoring and Control (EIM&C) of the organisational change by ONR will be required, with particular attention in the areas of governance of implementation and effective operation of the gated review process.
Based on the evidence sampled during this inspection measured against ONR’s expectations for LC36 (Organisational Capability), for the management of organisational change with respect to LC36 (2) and LC36 (5), I judged that the intervention rating is GREEN (no formal action), with identification of four areas of good practice, five regulatory observations (areas for improvement) and no regulatory issues.