Office for Nuclear Regulation

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Quarterly site report for BAE Systems Marine Limited, Devonshire Dock ComplexBarrow-in-Furness

October to December 2011


This report is issued as part of the Office for Nuclear Regulations (ONR) commitment to make information about inspection and regulatory activities relating to the BAE Systems Marine Limited Devonshire Dock Complex, Barrow-in-Furness available to the public. Reports are distributed quarterly to members of the BAE Systems Marine Limited Local Liaison Committee and are also available on the ONR website.

Site inspectors from ONR usually attend the BAE Systems Marine Limited Local Liaison Committee and will respond to any questions raised there by the members of the group. Any other person wishing to inquire about matters covered by this report should contact the ONR.

Post: Office for Nuclear Regulation
Redgrave Court
Merton Road
L20 7HS


The ONR Site Inspector made inspections on the following dates during the quarter:

Specialist inspectors carried out inspections on the following dates during the quarter:

The Superintending Inspector for Naval Nuclear Propulsion Plant Inspection visited the site on the following dates during the quarter:

The Deputy Chief Inspector for the Defence Programme visited the site on the following date during the quarter:

Some of the inspections were carried out with inspectors from the Ministry of Defence internal regulatory organisation, the Defence Nuclear Safety Regulator (DNSR).

Routine matters

Inspections at BAE Systems Marine Limited (BAESM)

Inspections are undertaken as part of the process for monitoring compliance with:

  1. the conditions attached by HSE / ONR to the nuclear site licence;
  2. the Health and Safety at Work etc Act (HSWA) 1974; and
  3. regulations made under the HSWA (for example the Ionising Radiations Regulations 1999 and the Management of Health and Safety at Work Regulations 1999).

This entails monitoring licensees actions on the site in relation to incidents, operations, maintenance, projects, modifications, safety case changes and any other matters which may affect safety. The licensee is required to make and implement adequate arrangements under the conditions attached to the licence in order to ensure legal compliance. Inspections seek to judge both the adequacy of these arrangements and their implementation. In this period routine inspections of BAESM covered:

In general the arrangements made and implemented by BAESM in response to safety requirements were deemed to be adequate in the areas inspected. However, where improvements were considered necessary, satisfactory commitments to address the issues were made by or are being sought from the licensee, and the site inspector will monitor progress during future visits. Where necessary, formal regulatory enforcement action will be taken to ensure that appropriate remedial measures are implemented to reasonably practicable timescales.

Emergency Preparedness

Following a successful demonstration of the majority of BAESM emergency arrangements on 17 August 2011, ONR attended another demonstration exercise on the 19th October 2011 to test the remaining elements of the emergency plan; namely the shelter station policy, accountability of personnel on the Licensed Site and the First Attack Fire Fighting Team (FAFFT).

A number of aspects of this demonstration exercise performed well particularly the FAFFT and the shelter station policy. However, due to a number of anomalies with the personnel electronic accounting system and incorrect personnel actions, it was not possible to account for all personnel in the Devonshire Dock Complex following evacuation to the relevant muster stations. As a consequence BAESM was requested to re-demonstrate the accountability aspects of their emergency arrangements.

The re-demonstration exercise took place on the 15th November 2011. Unfortunately, despite the fact that BAESM has upgraded the software, the exercise highlighted that a number of anomalies still remain with electronic accounting system. BAESM has therefore been requesting to investigate and rectify the cause of these anomalies or, if this work is unable to be successfully completed before power range testing on HMS Ambush, present a suitable alternative process to account for personnel.

An adequate demonstration of staff accountability is required before permission will be granted by ONR to commence power range testing on HMS Ambush.

Leadership and Management for Safety

An ONR specialist inspector attended site for an update on progress with the BAESM safety culture improvement programme following the ONR 2010 deep slice review of safety culture. Although this work is still in its infancy, ONR believes BAESM are moving in the right direction and will continue to offer advice and support whilst monitoring progress.

Annual Review of Safety

The ONR Superintending Inspector for Naval Nuclear Propulsion Plant Inspection and the ONR Site Inspector attended the annual review of safety. An annual review of safety is considered by ONR to be an opportunity for Licensees to carry out a formal review of their safety performance in the previous year, with a look ahead to the challenges and opportunities for the forthcoming year. This practice is undertaken on most of the UK nuclear sites and is considered beneficial and best practice. This was the first year that BAESM had undertaken this process and have learnt valuable lessons from this.


The ONR site inspector has carried out a number of interventions to support the Regulatory decision for commencement of power range testing on HMS Ambush. These included Examination, Maintenance, Inspection and testing of those safety systems required for power range testing as well as the maturity of the safety case. Unfortunately due to delays in the programme, BAESM was not yet in a position to formally request permission for commencement of this activity.

Non-routine matters

Licensees are required to have arrangements to respond to non-routine matters and events. ONR inspectors judge the adequacy of the licensees response, including actions taken to implement any necessary improvements. There were no matters of note to report during the current period.

Regulatory activity

Under health and safety legislation, ONR site inspectors, and other HSE inspectors, may issue formal documents to ensure compliance with regulatory requirements. Under nuclear site licence conditions, ONR issues regulatory documents, which either permit an activity or require some form of action to be taken; these are usually collectively termed Licence Instruments, but can take other forms. In addition, inspectors may issue enforcement notices to secure improvements to safety. There were no Licence Instruments issued during this quarter.

News from ONR

Final Fukushima report

The final report, 11 October, revealed no fundamental safety weaknesses in the UK's nuclear industry but concluded that by learning lessons it can be made even safer. The report, the Governments response and a podcast featuring Mike Weightman is available on the ONR website. A report will be published next year on progress in implementing the lessons for the UK.

Radioactive Materials Transport Team (RMTT) join ONR

The team joined ONR from the Department of Transport on 24 October. The team is responsible for regulating the transport of radioactive material by road and rail in Great Britain, as well as advising on transport by sea and air within the United Kingdom.  Their remit covers the transport of material to and from licensed nuclear sites and non-nuclear sectors such as hospitals and education establishments.  

Non Governmental Organisations Forum

ONR's second NGO forum was held in London (17 November). Topics covered included openness and transparency, generic design assessment and the final Fukushima report. The forum was well attended with constructive discussion sessions. Minutes will be published on ONR's website and a third forum will be held in April 2012.

International Physical Protection Advisory Service (IPPAS) mission

A team of international nuclear security experts led by the International Atomic Energy Agency (IAEA) visited the UK in October to assess civil nuclear security arrangements. They concluded the state of civil nuclear security in the UK to be sufficiently robust and identified many examples of good practice within the civil nuclear security regime and a number of valuable recommendations and suggestions.

Senior Representatives Conference

The annual event bought together nuclear industry leaders on 14 November. Discussions focused on: openness and transparency in the post-Fukushima era; promoting a safety culture across all parts of the nuclear industry supply chain; and responding to challenges post-Fukushima.

ONR public consultation update

The 12 week public consultation to clarify ONR's interpretation of bulk quantities relating to radioactive matter closed on 12 December. ONR is now analysing responses to the consultation and will make a policy announcement once a suitable definition is agreed.

Stress tests

ONR received the progress reports from licensees for UK non nuclear power plants by the required date of 15 October. Final reports are due by 31 December with a report due for publication in Spring 2012.

ONR received the final stress tests reports from licensees of UK nuclear power plants by the required date of 31 October. ONR will independently review these reports and provide a UK national report for the European Council by the end of December.

Generic Design Assessment

On 14 December generic designs for EDF and Areva's UK EPR and Westinghouse's AP1000 reactors were granted interim acceptance by ONR and the Environment Agency. However, neither reactor can be built in the UK until a number of issues are resolved.

ONR published its second quarterly report on 8 November.