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Licence Condition 13, Nuclear Safety Committee, compliance inspection (Remote)

  • Site: Barrow
  • IR number: 20-072
  • Date: October 2020
  • LC numbers: 13

Executive summary

Purpose of Intervention

This intervention at the BAE Systems Marine Limited (BAESML) licensed site at Barrow was undertaken as part of a planned series of inspections during 2020/21.  The intervention was conducted remotely due to the COVID-19 pandemic. The purpose of this inspection was to judge the extent to which the licensee complies with Licence Condition (LC) 13, which requires the licensee to have a Nuclear Safety Committee to provide it with nuclear safety advice.

Interventions Carried Out by ONR

On the 22nd October 2020 an ONR Operating Facilities Division (Defence Propulsion) Leadership and Management for Safety (LMfS) Specialist Inspector undertook an LC13 inspection of BAESML.

ONR utilised the following guidance during this intervention: ONR Nuclear Safety Technical Inspection Guide (TIG) NS-INSP-GD-013 Revision 6 – LC 13 Nuclear Safety Committee.

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A

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

The NSC is operating in accordance with its approved Terms of Reference, is providing challenge and advice, and the improvements identified by the licensee and ONR have been satisfactorily addressed since relicensing of BAESML in 2018. Observed strengths included periodic review and tracking of NSC members qualifications and experience, provision of NSC guidance (including behaviours and challenge), surveillance by the licensee Independent Nuclear Assurance function and self-assessment of NSC effectiveness.

Four observations or areas for improvement were identified during the intervention, as follows:

  • NSC Action Completion. I recommended that the licensee consider an improved approach for timely action completion and consider providing increased clarity on action priority, time for completion and expectations.
  • Provision of NSC Papers.  I recommended that the licensee consider an improved approach for the timely provision of NSC papers and share expectations for routinely meeting the fourteen-day guidance for provision of papers to NSC members.
  • Resilience of NSC Membership. To support future development of the NSC, in harmony with the nuclear safety requirements of the licensed site and the skills and experience of licensee staff, I recommended that BAESML consider establishing a succession plan for NSC membership and management.
  • NSC Learning. I noted that BAESML have carried out some NSC learning exchanges with another licensee in the defence propulsion area and observed that shared learning was a positive input to the improvements in NSC management and conduct which BAESML have delivered over the last 3 years.  I recommended that BAESML continue and seek further opportunities for NSC learning from other relevant licensees to ensure that these improvements are sustained and form a basis for continuous improvement.

Based on the evidence obtained during the intervention, I judged that BAESML have adequately addressed the improvement areas identified in the Level 4 Regulatory Issue 6656 (NSC Improvements), have completed the associated improvement actions and therefore recommended closure of Regulatory Issue 6656.  A future observation of the BAESML NSC at site is planned by ONR for early 2021.

Conclusion of Intervention

Based on the evidence sampled during the intervention I judged that measured against ONR’s expectations for LC13 (Nuclear Safety Committee), the intervention rating is GREEN (no formal action), with identification of four areas of good practice, four regulatory observations (areas for improvement), closure of one Level 4 regulatory issue and no new  regulatory issues. The observations and recommendations were communicated to and accepted by the licensee during the intervention feedback.