Office for Nuclear Regulation

Fire Safety Inspection

Executive summary

Purpose of Intervention

This was a planned inspection of the BAE Systems Barrow site. The intervention carried out was in-line with the planned inspection programme contained in the BAE Systems Integrated Intervention Strategy (IIS).

The purpose of this intervention was to ensure that the Licensee is compliant with the requirements of the Regulatory Reform (Fire Safety) Order 2005.

Interventions Carried Out by ONR

This intervention was a planned Compliance Inspection undertaken in two parts. The initial intervention was completed remotely followed up with a site inspection. Both aspects of this intervention focused on the life safety requirements of the Regulatory Reform (Fire Safety) Order 2005.

The intervention was initially completed remotely due to COVID-19 restrictions, with an on-site visit taking place in December to allow further clarification of matters previously discussed. ONR could not therefore directly inspect the implementation of fire safety management procedures or assess directly the effectiveness of the activities being undertaken on the site or independently confirm actual compliance with company processes.

In advance of the inspection I informed the licensee that the I would focus on the conditions that relate to routine production / construction activities particularly in the DDH, focusing on the control and management of combustible loads and the delivery of materials to the vessels under construction. This also included discussions relating to fire safety within the site redevelopment project that are currently under the control of contractors.

Explanation of Judgement if Safety System Not Judged to be Adequate

NOT APPLICABLE THIS WAS NOT A SYSTEM BASED INSPECTION

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

This intervention, along with previous interventions and engagement with the licensee, confirms my overall impression of a knowledgeable and experienced fire safety engineering team which applies a robust approach to fire safety. I am confident that fire safety is taken seriously and is given the due consideration it deserves. Working alongside and in support of the Fire Engineering Team (FET) are a group of Fire and Incident Liaison Officers (FILO) who themselves are part of the BAE Fire and Rescue Service (BAE FRS). Due to the nature of the production activities fire has, for many years, been identified as a significant risk. My meetings throughout the two days of meetings has provided me with the confidence that the risk posed from fire and the importance of managing this risk is fully understood.

My intervention provided me with an opportunity, through a series of telephone meetings, to discuss aspects of the fire safety arrangements within the DDH and the D59 construction project. The current FET and FILO team provide an experienced and embedded fire safety resource across the licensed site. The dynamic nature of the work activities within the DDH will continue to require an on-going assessment of risk from fire and the implementation of suitable risk reduction measures. The same applies across all construction projects. The team contained within the FET are suitably positioned to offer a robust Intelligent Customer (IC) role for the SRP projects.

I held a meeting with the Principal Fire Manager who provided a detailed description of the on-going development of the BAE FRS. Since my previous intervention BAE have considered his business case to increase the size of the Incident Response capability at site and have agreed with the argument that an increase in the available resource is appropriate. This has followed the understanding of the findings of a “deep dive” review of the current arrangements relating to both the Incident Response Team, and the Hot Work / Fire Watcher arrangements on site that was conducted earlier in 2019.

During my meetings with those from BAE who have IC responsibilities for the D59 construction project, our discussions exposed a number of areas of challenge relating to the use of air horns in relation to the means for raising the alarm in the event of a fire for the D58 project. Clarity will be provided describing the use of the air horns and the means by which their use can be guaranteed. This will include an understanding as to who has responsibilities for their operation and how this will be guaranteed.

Some areas for improvement have been identified regarding the condition of fire doors, the control of combustibles, the use of laydown areas, and the induction of personnel.

Conclusion of Intervention

I concluded with an assessment of compliance with the legislation at a meeting held on the 12th November, and I presented areas for improvement and expected actions to address them at a post inspection meeting with senior managers. Although badged as a Conventional Fire Safety Inspection, the sessions arranged have addressed elements of relevant Nuclear Fire Safety issues. These are reported separately in two Contact Records (CM9 2020/308559 and 308565). These have been completed by an ONR Internal Hazards Inspector.

The inspection outcome was rated as GREEN.