I led a remote team inspection at the BAE Systems Marine Limited’s Barrow-in-Furness site, which covered the licensed Devonshire Dock Complex. It was undertaken as part of the 2020/21 intervention plan and propulsion sub-division strategy, and timed to provide advice and guidance ahead of the 2025 periodic review of safety.
The inspection was carried out remotely by telephone. An inspector from the Defence Nuclear Safety Regulator (DNSR) participated in the inspection.
This Intervention covered Licence Condition 15 (Periodic Review).
The team targeted:
During the inspection I held discussions with personnel from senior management through to operational levels. I also sampled relevant documentation to see how the arrangements are being implemented. I assessed compliance using the following guidance:
From the evidence presented during the inspection, I am of the opinion that the licensee has adequate arrangements for compliance with LC15. However, the licensee does not yet have in place sufficient evidence to demonstrate full implementation of its periodic review process.
I consider that the development of the rolling review process has addressed the shortfalls in the previous PRS process. The documents I reviewed showed a detailed, well thought through explanation of the licensee’s process. In reviewing the documents, I noted that there is also now a clear integration of Relevant Good Practice (RGP) into the heart of the PRS process, and evidence that RGP is being met, or is being developed. Through the development of this new process I have also seen a good degree of internal challenge from the Internal Nuclear Assurance Team (INA).
I consider that BAESML has made significant progress in gathering the evidence to demonstrate implementation of the PRS rolling review process. Across the suite of documents which currently exist, there is evidence that key elements of RGP have been identified. In addition, the assessments carried out seemed to provide a thorough review of the available information. This is an improving position, and further work is required to link the RGP evidence through to processes and the safety case. Safety Factor (SF) owners from the first rolling review were clearly knowledgeable of the matters raised (by the PRS Technical lead) and showed good leadership with respect to the issues identified. I would have no concerns with these SF owners taking over from the PRS technical lead for the next Annual Review of Safety rolling review.
In my opinion the process should cover the full scope of what is required by a PRS, but there is still the potential that some of the work required may not be identified until towards the end of the 10 year PRS period. This is an area of risk. In addition, by tying the PRS programme to the boat build Hold Points any delay in the programme could result in fewer Hold Point reviews being carried out in the set period. Therefore, there is a risk that if less evidence is available, additional work could be required to show that RGP is being met. Notwithstanding this concern, the licensee has scheduled a suitable interim review point which should identify any gaps in the information required for the PRS and provide sufficient time to manage them. This may result in the licensee using methods retained from the previous PRS process which are still embedded within their arrangements. Hence, I am content that the arrangements proposed are satisfactory to show compliance with LC15.
I advised BAESML that they should continue to develop their RGP document suite and should consider widening their scope beyond ONR SAPs, TIGs and TAGs to include industry standards and practices. The rolling review documents provide a RAG rating for the Safety Factors and the basis for this needs to be clear. I advised BAESML that they should formally track the ‘recommendations’ and ‘observations’ identified within the rolling review reports within their management system. I am satisfied that BAESML recognised and understood the shortfalls identified in the inspection and intends to carry out the necessary work to address these. I have confidence that, once the proposed further work has been completed, BAESML will be in a better position to demonstrate LC compliance with respect to implementation of their arrangements.
I noted a number of opportunities for improvement during the inspection and these have been recorded as regulatory observations and shared with the licensee. The main observation was:
In response to this observation a single Level 4 Regulatory Issue is raised for the licensee:
Based on the sampling undertaken during the intervention I am satisfied that in general the licensee has in place adequate arrangements under Licence Condition 15 Periodic Review. I therefore assign a rating of Green (no formal action) to the arrangements part of this intervention. I was unable to provide a rating for the implementation of the arrangements due to the fact that BAESML has yet to fully apply the new process Safety Factors linked to the boat build hold points.