- Site: Barrow
- IR number: 22-024
- Date: May 2022
- LC numbers: 26
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) 26 – Control and supervision of operations. This inspection formed part of ONR’s Integrated Intervention Strategy for 2022/23.
The purpose of this inspection was to gain confidence that BAESML’s arrangements for LC26 meet regulatory expectations and that they are adequately implemented for activities involving critical operations for Astute boat 5 (Anson).
This inspection was a joint inspection with the Defence Nuclear Safety Regulator, for the equivalent Authorisation Condition 26 Control and supervision of operations.
Interventions Carried Out by ONR
LC26 requires the licensee to ensure that no operations are carried out which may affect safety except under the control and supervision of suitably qualified and experienced persons appointed for that purpose by the licensee.
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 scope for the inspection including:
- To obtain assurance that BAESML has an appropriate organisation for control, supervision, and governance during critical operations. To include the clear line of control through the organisation and to include control of both Submarine Plant and Site facilities activities.
- To obtain assurance that BAESML have appropriate management arrangements that supports control, supervision, and governance during critical operations.
- Implementation of the control, supervision, and governance arrangements for sampled areas.
- To obtain assurance on effective decision making within critical operations including permission of activities, assessment of results, and management of emergent issues.
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
The inspection reviewed the overarching organisation and arrangements for the control and supervision for critical operations and explored in detail the roles with assigned individuals. All we spoke to were able to convey their roles and responsibilities associated to critical operations activities and all conveyed the LfE from the previous boat which was reflective of the improvements the Test and Commissioning team have put in place for control and supervision of operations.
Roles and responsibilities were an area that took time to understand within the arrangements. The inspection team acknowledged the complexity of the arrangements given the layers of supervision, the different organisations involved and the need to integrate with established arrangements used outside critical operations, however simplification of arrangements to aid understanding should remain a goal. We obtained the clarity we needed to inform our discussions with those with roles and responsibilities from the Reactor Test Group (RTG) Chairman and the In-Water Director.
The critical operations safety case document provides an enabler for wider compliance with other Licence Conditions. The inspection team have seen evidence during this inspection where the timing of the safety case approval is having an adverse effect on the downstream activities such as briefings, Duly Authorised Person boards, and the finalisation of operating instruction being examples. However, we are content that this will be adequately addressed by BAESML’s own governance arrangements prior to start of critical operations.
We considered the control documentation for the activity and discussed how it was utilised in practice along with the Plan of the Day process, which we observed and found to be well structured, well managed and with good configuration control. Overall, this provides a robust control of critical operations with appropriate layered supervision and clear control through the RTG was shown. This enabled demonstration that adequate control and supervision arrangements are in place with consistent understanding of the key roles regarding the implementation.
Conclusion of Intervention
We judge that BAESML has adequately demonstrated compliance against LC26 – Control and supervision of operations for the chosen sample, meeting relevant good practices and providing supporting evidence for the future release of the regulatory hold point for critical operations.
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.