Executive summary
Date(s) of inspection: February 2024
Aim of inspection
This was a planned Licence Condition 11 compliance inspection that sought to obtain confidence (by sample) that BAE Systems Marine Limited (BAESML) has made and implemented adequate arrangements for dealing with any accident or emergency arising on the site and their effects. This includes identification by the licensee of all events that might lead to a radiation emergency, including those that are beyond the design basis.
The inspection was conducted on-site by the ONR nominated site inspector alongside the Defence Nuclear Safety Regulator's (DNSR) Principal Inspector for Reactor Build.
Subject(s) of inspection
- LC11 - Emergency arrangements - Rating: Amber
Key findings, inspector's opinions and reasons for judgement made
This Licence Condition (LC) 11 "Emergency Arrangements" compliance inspection focused on the evidence provided by BAE Systems Marine Limited (BAESML) in the areas of capability map outcomes #2 'Anticipation' and #6 'Response'.
I welcome BAESML's improved performances during recent level 1 demonstration exercises, which have been driven by an increase in, and focus on, training. However, evidence gathered during this intervention suggests that the underlying arrangements themselves require improvement, particularly in the demonstration that the complete range of activities that may give rise to events and incidents on the site has been captured, thereby providing confidence in BAESMLs basis for its emergency response capability (people, plant and process). At present, BAESML's (nuclear) response is focused primarily on emergency response to events during Power Range Testing (PRT), and other activities have significantly less attention.
I have confidence in the leadership of the Resilience team; the Principal Resilience Manager was proactive and shared the range of improvements identified. However, there is not currently an integrated improvement plan in place, and improvements are being managed in a reactive manner at present. Improvements in the governance of the emergency arrangements, through the Site Emergency Planning Committee are required in the short term, so as to support the Principal Resilience Manager on decision making, prioritisation and accountability matters.
Though ONR has seen improvements in recent level 1 demonstration exercises, I observed more evidence during this inspection that BAESML must begin to increase the challenge and complexity of the emergency response demonstrations, so as to build further confidence in the overall emergency response, when all elements of the plans will be in motion. BAESML should work towards an appropriate level of complexity ahead of the next scheduled PRTs. I judged that the on site fire and rescue service trained to a good level and its approach to emergency response was in line with (and in parts, beyond) other UK-based fire and rescue services.
Conclusion
Based on the sample taken during the inspection, I rate the LC11 intervention as amber - 'Seek Improvement'. This rating is in line with the established ONR guidance (ONR-INSP-GD-064):
- Significant shortfall against an identified relevant good practice when compared with appropriate benchmarks.
- Significant or systematic failure to implement or meet compliance arrangements.
Whilst none of the findings in the inspection presented an immediate or direct risk to nuclear safety, ONR recognises the importance that an effective emergency response has in the mitigation of the consequences in the event of an incident on site. I have therefore raised a level 3 regulatory issue (RI-11958) to track the improvements required to BAE System Marine Limited's emergency arrangements. The actions within the RI will focus on implementation of a robust governance process and the development of an improvement plan; aligning with the items mentioned in the Executive Summary.