Skip to content

Barrow - Safety intervention - Decision making

  • Site: Barrow
  • IR number: 19-021
  • Date: May 2019
  • LC numbers: 36

Executive summary

Purpose of Intervention

The purpose of this joint ONR, DNSR and BAESML INA intervention was to undertake a planned inspection at BAESML, Barrow, in accordance with ONR’s Intervention Plan for the regulation of BAESML 2019/20.

Interventions Carried Out by ONR

ONR Inspectors, DNSR Inspectors and BAESML INA Engineers (collectively termed ‘the Inspectors’ in this IR) undertook an LMfS intervention to examine BAESML’s application of LC36 arrangements in respect of safety related decision making, including a LC36 (Organisational Capability) compliance rating.

ONR utilised the following guidance during this inspection: ONR Nuclear Safety Assessment Principles, 2014 edition (Revision 0, November 2014); ONR Nuclear Safety Technical Assessment Guide (TAG) 080, NS-TAST-GD-080 Rev. 3, Challenge Culture, Independent Challenge Capability (including an Internal Regulation function) and the provision of Nuclear Safety Advice;  ONR Nuclear Safety Technical Assessment Guide (TAG) 093, NS-TAST-GD-093 Rev. 2, Guidance for Undertaking LMfS Reviews;  and WANO Principles PL 2013-1, Traits of a Healthy Nuclear Safety Culture, May 2013.

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A – this was not a Safety System inspection.

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

On the basis of the areas sampled during the intervention, the Inspectors judged that BAESML had adequately applied their LC36 arrangements in respect of safety related decision making and no major shortfalls were identified.

Three areas of good practice for safety related decision making were identified during the intervention, as follows:

  • Introduction and development of the Corrective Action Board.
  • Role of the safety authorisation groups in decision making:
    • Safety authorisation group processes and the conduct of the respective Chairs.
    • Evidence of a prudent approach for safety and the application of principles of conservative decision making.
  • Active challenge mechanisms inherent in the licensee’s decision making process for operational readiness reviews.

Five regulatory observations (areas for improvement) were identified during the intervention, as follows:

  • BAESML should incorporate decision making learning, obtained during the return to work review activities, into their arrangements for operational readiness reviews and assess the effectiveness following an appropriate period of implementation.
  • BAESML should review Operational Decision Making (ODM) and Conservative Decision Making (CDM) learning from other licensees, in the area of key safety factors for decision making, and consider the provision of guidance for operational teams, commissioning teams and authorisation groups.
  • BAESML should give attention to development of SQEP staff to fill the roles of safety authorisation group Chairs and members (key decision making roles) and establish robust succession plans.
  • BAESML should ensure that safety authorisation groups accurately record the rationale for decision making and thereby provide adequate demonstration of Conservative Decision Making (CDM). The licensee should consider the provision of appropriate guidance to safety authorisation groups and / or an exemplar case study, in which an accurate record of the rationale for safety related decision making is evident.
  • BAESML should implement improvements to the design of the safety assurance framework, to maximise organisational learning and facilitate enhanced active challenge mechanisms.

During the intervention, the Inspectors observed that the licensee’s safety committee framework appeared complex, with potential for some duplication, and questioned the effectiveness of oversight, coordination and accountability.  ONR Inspectors noted that ONR’s Integrated Intervention Strategy for BAESML includes an LC13 intervention in late 2019, and advised the licensee that ONR plan to incorporate the review of safety committee arrangements and effectiveness into the scheduled LC13 intervention.

Conclusion of Intervention

Based on the evidence sampled during this inspection, the Inspectors judged that measured against ONR’s expectations for LC36 (Organisational Capability) and safety related decision making (ONR SAPs, TAGs and RGP), the intervention rating is GREEN (no formal action), with identification of three areas of good practice, five regulatory observations (areas for improvement) and no regulatory issues.