- Site: Barrow
- IR number: 21-157
- Date: March 2022
- LC numbers: 12, 36
Executive summary
Purpose of Intervention
This inspection focussed on BAE Systems Marine Ltd (BAESML) arrangements for compliance with Licence Condition (LC) 12 (Duly authorised and other suitably qualified and experienced persons) and LC 36 (Organisational Capability). This inspection formed part of ONR’s Integrated Intervention Strategy for 2021/22.
The purpose of this inspection was to gain confidence that BAESML arrangements for LC 12 and LC 36 meet regulatory expectations and to gain confidence that BAESML arrangements are adequately implemented.
Interventions Carried Out by ONR
During the inspection, we assessed the adequacy of BAESML arrangements for LC 12 and LC 36 and assessed the adequacy of their implementation. To achieve this we:
- Assessed BAESML arrangements for LC 12 and LC 36 against relevant ONR guidance documents.
- Inspected the Nuclear Baseline (NB) and assessed the adequacy of its management.
- Inspected the competency records for a sample of BAESML staff and contractors who hold roles on the NB.
- Inspected a sample of Management of change (MOC) submissions and assessed the categorisation (including aggregation and governance), and the management of MOC implementation plans, risk management and close-out.
- Explored BAESML staff understanding of the competency and change management arrangements.
Explanation of Judgement if Safety System Not Judged to be Adequate
NOT APPLICABLE THIS WAS NOT A SYSTEM BASED INSPECTION
Key Findings, Inspector's Opinions and Reasons for Judgements Made
BAESML have recently improved their competency management arrangements in response to regulatory challenge. We judged that BAESML’s revised arrangements for LC 12 broadly meet regulatory expectations and that BAESML were able to demonstrate the competency of a sample of individuals who hold roles on the nuclear baseline. We found that individuals spoken to were knowledgeable about the revised competency management process. Finally, we judged that revised arrangements for Duly Authorised Person (DAP) appointments adequately tests the competency of individuals, prior to confirming them in post.
This said, we identified some areas for further improvement. Firstly, it was not clear how BAESML will use their improved competency data to inform decision making at an individual, functional and organisational level. Secondly, we considered that BAESML LC 12 arrangements could be further simplified, with consistency improved across the document suite to improve useability. Finally, we found that individual role profiles could be rationalised and simplified, to minimise the burden of completing competency assessments and to ensure the level of proficiency expected is consistent with the requirements of the role. During the inspection, we gained confidence that BAESML have an improvement programme which covers these aspects. Given the large scope of this programme and the potential impact to LC 12 compliance, we will continue to monitor the progress.
We undertook an inspection against LC36 which examined BAESML’s arrangements to maintain adequate human and financial resources. Based on a sample of the NB and discussions concerning management of human resources, including resource management, succession planning, vulnerability/risk assessment and management of change, we were satisfied that BAESML has effective processes necessary to support safe operation of the nuclear licensed site.
The NB was presented and discussed by leaders in the Nuclear Discipline Skills and Capability (NDSC) team and it was reported how posts and roles significant to nuclear safety are identified in the system, and how they are monitored and managed. The NB was presented showing the organisation, and included non nuclear roles such that overall resources and management demand was visible. This is being transitioned onto new software platforms and we consider this an effective way of demonstrating the availability of a capable organisation. The quarterly review mechanism of using Form 123 Part 1 and Part 2 appeared to be an appropriate way of demonstrating that the NB is up to date, however the licensee needs to improve routine management and governance of the supporting reporting processes.
Oversight arrangements were reviewed, including the Nuclear Capability Integrated Work Team Meeting (NCIWT), which has a key role in providing oversight and assurance of the LC10, 12 and 36 arrangements. We consider the effectiveness of this meeting to be central to the continued effective implementation of the LC36 arrangements and will review the performance of this meeting over the coming twelve months.
We examined examples of planned, implementation phase, and completed organisational change proposals and confirmed compliance with the Licensee’s Management of change arrangements, in the areas sampled.
Conclusion of Intervention
We judged that BAESML’s arrangements for LC 12 met regulatory expectations and that they were able to demonstrate the competency of a sample of individuals who hold roles on the nuclear baseline. As such we rate the LC 12 aspects of the inspection as GREEN.
However, we concluded that, given the scope, scale and importance of the current LC 12 improvements, a level 4 regulatory issue is appropriate, to track progress of the improvements to completion.
On the basis of the areas sampled during the intervention we judged that BAESML had established adequate arrangements for LC36 compliance in the areas of management of change and organisational capability. There was evidence that the licensee has effectively applied their LC36 arrangements in the production of MOC proposals, good practice had been applied in many areas, and a continuing improvement approach has been established. No major shortfalls with LC36 compliance were identified during the intervention.
For LC 36 compliance, we rated the inspection as GREEN (no formal action) and the areas for improvement identified will be tracked through routine regulatory engagements. ONR will undertake a follow-up regulatory engagement to consider the effectiveness and efficacy of the governance arrangements for LC36, including sampling the NCIWT meetings.
During the intervention we witnessed potential issues associated with workload and capability resilience within the NDSC team, which could impact delivery of the improvements identified to the LC 12 and 36 arrangements. We raised this with the newly appointed Nuclear Safety and Security Director, who welcomed the challenge and stated that they were beginning a process of organisational design. We will continue to monitor this through normal regulatory business.
The issues raised in this report were shared during the closing meeting with the licensee, and were accepted by the licensee organisation.