- Site: Barrow
- IR number: 21-151
- Date: January 2022
- LC numbers: 4
Executive summary
Purpose of Intervention
The purpose of this intervention was to undertake a Licence Condition compliance inspection at BAE Systems Marine Limited (BAESML) against Licence Condition (LC) 4 – Restrictions on nuclear matter on the site.
This was inspection is related to the Astute Boat 6 Build for Product To Site (PTS) readiness activities as identified in BAESML’s Hold Point Control Document. This inspection will provide part of the evidence for release of this hold point.
Interventions Carried Out by ONR
LC4 requires the licensee to ensure that adequate arrangements are made for nuclear matter being brought onto the site and for storing it.
The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.
This inspection, comprised of review of related documentation, discussions with BAESML staff and walkdown of the facilities, with the focus being to:
- Assess the adequacy of the LC4 arrangements (specifically LC4(1) and LC4(2).
- Confirm how any conditions for acceptance are identified and articulated to the donor site and how BAESML has assured itself that the QA arrangements of the donor site are suitable and sufficient to assure that the conditions for acceptance will be achieved.
- Confirm that an adequate safety case for receipt and storage is in place and identifies any operating rules.
- Sample the procedures and records covering all activities involved in bringing and storage of nuclear matter on to the site and that there is golden thread through to these from any safety case requirements.
- Sample roles identified within the arrangements for control and supervision and verify training records to carry out roles identified to determine that there are adequate numbers of appropriately trained staff for this activity.
- Determine the access and storage arrangements including provision for receipt, inspection, monitoring and retrieval of nuclear matter in the New Core Facility (NCF).
- Verify that appropriate examination, inspection, maintenance, and testing has been carried out in accordance with LC 28 (Examination, inspection, maintenance, and testing), to confirm compliance with safety requirements whilst nuclear matter is in storage.
Explanation of Judgement if Safety System Not Judged to be Adequate
Not Applicable – this was not a System Based Inspection (SBI).
Key Findings, Inspector's Opinions and Reasons for Judgements Made
From review of the arrangements and sampling of operational records, we consider that the licensee does effectively implement their arrangements for LC4 – Restrictions on nuclear matter on the site and meets relevant good practice as identified in the LC4 Technical Inspection Guide (TIG).
We were content that the Astute Boat 6 Build for PTS readiness activities were maturing and the arrangements sampled were supporting this.
We were able to confirm sound alignment between the arrangements and implementation for Safety Case preparation and the identification of operating rules, operational documentation, maintenance and the training, experience and expectations for roles with responsibilities for the product to site activity. We carried out a walkdown of the facility to sample the status of readiness and we were content.
We considered that conditions for acceptance were difficult to identify through documentation sampled during the inspection and requested that BAESML look to strengthen this aspect of their arrangements. A Level 4 Regulatory Issue will be raised to monitor improvements.
Conclusion of Intervention
We judge that BAESML has adequately demonstrated compliance against LC4 ‘Restrictions on nuclear matter on site’, meeting relevant good practices and providing supporting evidence for the future release of the product to site hold point.
We therefore consider, noting the ONR guidance on inspection ratings, that an inspection rating of GREEN (no formal action required) is merited for the licence condition inspected.