- Site: Barrow
- IR number: 21-044
- Date: June 2021
- 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 2021/22.
The ONR inspector and DNSR inspector (collectively termed ‘the inspectors’ in this Intervention Record) undertook a Leadership and Management for Safety (LMfS) intervention to examine the progress made by BAESML in progressing LMfS improvement themes, the development of the INA capability, and improvements to the safety assurance framework.
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 1, January 2020); ONR Nuclear Safety Technical Assessment Guide (TAG) 080, NS-TAST-GD-080 Rev. 4; Challenge Culture, Independent Challenge Capability (including an Internal Regulation function) and the provision of Nuclear Safety Advice; ONR Nuclear Safety Technical Assessment Guide (TAG) 048, NS-TAST-GD-048 Rev. 6; and Organisational Change 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, regulatory compliance engineers and the INA functional line. The intervention also included the sampling of LMfS improvement actions 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 implemented improvements were identified during the intervention, as follows:
- Development of the licence compliance dashboard and inclusion of observed good practices, to facilitate learning and sharing across the organisation.
- Establishment of a set of LMfS principles and criteria, based upon external good practice, to guide INA engineers in their surveillance and inspection activities.
- Strengthened organisational capability of the INA team, through the filling of all identified vacancies and establishing competence development plans.
- Initiation of the ‘Prosafe’ and ‘Zero Harm’ safety improvement programmes, associated staff engagement, positive influence of safety behaviours, and identification of safety priorities.
Four regulatory observations (areas for improvement) were identified during the intervention:
- The leadership team should consider current safety related action completion against the recommendations for good practice (independent challenge) and seek improvement, particularly for actions raised by the internal regulator function and by external regulators.
- The licensee should review its safety reporting processes to the senior leadership team to ensure that priority safety messages are appropriately highlighted and emphasised.
- Arrange for an external peer review of BAESML’s INA function, to assist in learning and continued strengthening of the licensee INA capability.
- At an appropriate future stage of the implementation of the safety and behavioural improvement programmes, undertake an impact review or benefits realisation activity to understand whether the programmes are delivering the anticipated behavioural and cultural safety improvements.
Conclusion of the Intervention
Based upon the areas sampled during the intervention and the respective evidence, the inspectors judged that BAESML had tracked priority LMfS actions within their action management systems, made significant progress in completing these actions, continued to develop and strengthen the INA capability, and had established and maintained an approach to improve the integration and coordination of safety assurance activities.
The inspectors reviewed BAESML’s progress in implementing the Operational Experience Review Group (OERG) and judged that the approach and benefits realised had addressed the required safety assurance framework improvements and recommended closure of Regulatory Issue 7731 (Level 3). Continued development and sustainability of the OERG will be a theme of future regulatory engagements.
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 GREEN (no formal action), with identification of four areas of good practice, four regulatory observations (areas for improvement), and completion of Regulatory Issue 7731 (Level 3).