Office for Nuclear Regulation

BAE Systems Marine Ltd - LC7 compliance inspection

Executive summary

Purpose of Intervention

This intervention, conducted at BAE Systems Ltd. (BAESML), Barrow site, was undertaken as part of the 2019/20 intervention plan and ONR operating facilities propulsion sub-division strategy.

Interventions Carried Out by ONR

I conducted a Licence Condition (LC) 07 - Incidents on site, compliance inspection, which focused on the adequacy of the licensee’s arrangements, and their implementation. Following the previous ONR inspection, BAESML has made improvements to its arrangements following ONR advice; as such this inspection looked at the full scope of LC 07 arrangements including: notification, recording, investigating and reporting of such events occurring on site. The inspection also considered utilisation of learning outcomes, and implementation of further process improvements.

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

The inspection also considered International Atomic Energy Authority (IAEA) guidance NS-G-2.11: “A system for the feedback of experience from nuclear events in nuclear installations.” ONR considers the above Relevant Good Practice.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable.

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

Significant work has been completed by the licensee in responding to the findings from the previous ONR inspection, and work continues to progress positively in-line with an improvement plan.

I plan to agree actions with the licensee to resolve the compliance shortfalls I identified during this inspection. I will monitor progress of these via an ONR level 3 regulatory issue; as follows:

Level 3 regulatory issue – Deliver the LC 07 improvement plan, and verify, through internal assurance, that improvements have been adequately implemented.

[Detailed actions for addressing shortfalls identified as part of my inspection are listed               within the body of my Intervention Record, which has been provided to the licensee, and also recorded in ONR’s Regulatory Issues database].

Based on the sampling I undertook, I have confidence that BAESML will continue to deliver LC07 enhancements. This confidence is built on their self-identification of improvement areas, and their implementation of an electronic based incidents management system. However I have identified compliance shortfalls against LC 07 compliance during inspection and therefore rated the inspection as AMBER.

Conclusion of Intervention

Based on my inspection of the licensee’s arrangements for compliance with licence condition 07, I have identified areas of compliance shortfall against relevant good practice.

An ONR rating of AMBER requires a level 3 regulatory issue to be raised. I consider this to be proportionate, as the licensee, despite identifying and accepting a number of improvements, has not made sufficient progress with implementation of actions identified through previous inspections. BAESML continues to work to correct these shortfalls using an improvement plan, and I have agreed with BAESML that the level 3 regulatory issue will be used to monitor progress via routine regulatory business.