- Site: Barrow
- IR number: 19-085
- Date: September 2019
- LC numbers: 36
Executive summary
Purpose of Intervention
The purpose of this ONR / DNSR intervention was to undertake a planned inspection at BAESML, Barrow, in accordance with ONR’s Intervention Plan for the regulation of BAESML 2019/20.
ONR Inspectors and DNSR Inspectors (collectively termed ‘the Inspectors’ in this Intervention Record) undertook a Leadership and Management for Safety (LMfS) intervention to examine the health and capability of the Independent Nuclear Assurance (INA) team and the coordination / effectiveness of assurance activities carried out by the licensee.
Interventions Carried Out by ONR
ONR utilised the following guidance and Relevant Good Practice (RGP) 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 Independent Oversight, A Nuclear Industry Good Practice Guide, Issue 2, Dec. 2018.
The intervention was carried out through a series of structured discussions and group meetings with key personnel from the following functions: Nuclear Safety and Security, Quality, Operations, Programme Delivery, Engineering and Safety, Health and Environment (SHE). This included discussions with relevant directors, managers, senior operators, assurance engineers and the INA functional line. The intervention also included the sampling of two INA inspection activities / reports and structured discussions with nuclear safety related assurance functions within the licensee organisation.
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
Four areas of good practice and improvements implemented since the last inspection were identified:
- Organisational understanding / awareness of independent nuclear assurance and implementation of a mandate for the INA team - completion of Regulatory Issue 6422 (Level 3).
- INA team nuclear safety reporting and performance monitoring of the INA team.
- Inspection and surveillance actions ownership, progress and completion.
- Approach for competency assessment and development of the INA team.
One finding (ONR Regulatory Issue) and two regulatory observations (areas for improvement) were identified during the intervention:
- Limited progress in addressing safety assurance framework improvements. We raised a new Regulatory Issue (Level 3), for BAESML to address improvements to the safety assurance framework as a priority, in the context of the length of time that the topic has been identified as being significant for nuclear safety and requiring improvement (since 2017).
- BAESML should review the inspection and surveillance programme for inclusion of appropriate leadership and management for safety topics in the light of intelligence gathering, current operational risks and supporting development of inspectors in the INA team.
- BAESML should strengthen the organisational capability of the INA team, through the timely filling of vacancies and effective management of succession planning for leadership roles within the INA team.
Conclusion of the Intervention
On the basis of the areas sampled during the intervention, the Inspectors judged that the effectiveness of the INA team in providing independent challenge, assurance and nuclear safety advice to BAESML had continued to improve over the last two years, since the last ONR INA intervention in 2017, and provided a sound basis for continued improvement. There was evidence of significant improvement in establishing and implementing the INA mandate, such that the Inspectors were content to close the associated Regulatory Issue (Level 3).
The intervention also examined the health, capability and effectiveness of the wider assurance functions and framework, with respect to nuclear safety. The Inspectors observed limited progress in addressing the required safety assurance framework improvements and recommended enhanced attention by BAESML as a priority. This was identified by the Inspectors as a new Regulatory Issue (Level 3).
Based on the evidence sampled during this inspection, the Inspectors judged that measured against ONR’s expectations for a capable internal regulator function and effective nuclear safety related assurance, the intervention rating is AMBER (seek improvement), with identification of four areas of good practice, completion of Regulatory Issue 6422 (Level 3), two regulatory observations (areas for improvement) and one Regulatory Issue (Level 3).