Date(s) of inspection:
- August 2022
Aim of inspection
The inspection will be led by ONR to examine the adequacy and application of BAESML arrangements for Licence Condition (LC) 7 (Incidents on the Site).
The purpose of LC7 is to ensure that licensees have made and implemented adequate arrangements for the notification, recording, investigation and reporting of incidents on the site.
A key contribution to the continual improvement of any effective safety regime is that of organisational learning, including learning from incidents on the site. It is essential that licensees collect information on incidents occurring at nuclear installations throughout their lifetime, including deviations from normal performance by systems and by personnel, which could be a precursors to more significant incidents.
This intervention forms part of the ONR Integrated Intervention Strategy for the Regulation of BAESML during 22/23.
The intervention will include the following themes:
- Adequacy of BAESML arrangements for the notification, recording, investigation and reporting of incidents.
- Adequacy of the implementation of these arrangements across the organisation sampling how learning from incidents is analysed, actioned, and communicated.
Subject(s) of inspection
- LC7 – Incidents on the site – Rating: Green
Key findings, inspector’s opinions and reasons for judgement made
During this inspection, we gained evidence of how BAESML manage incidents on site in relation to notification, recording, investigation, reporting and learning. Specifically, we:
- Reviewed BAESML LC7 written arrangements
- Sampled how incidents are notified, recorded, investigated, reported and learnt from.
- Sampled how BAESML actions, trends, learns and disseminates learning from these incidents.
The inspection was carried out in line with ONR’s Technical Inspection Guide NS-INSP-GD-007 Issue 6.1.
From our sample of the BAESML arrangements these were adequate and gave good coverage of notifying, reporting, recording and investigating.
In a number of areas we identified good practices, including: easy to use reporting software, well written actions, sound written arrangements, good levels of governance and good trending arrangements within the software.
There were opportunities for improvement identified from the inspection:
- A lack of consistency in the implementation of arrangements across the business units.
- A lack of an underpinned, resourced plan for making improvements to the arrangements in areas including; action effectiveness reviews, the Local Investigation Screening Groups and investigation timeliness.
- Inefficiencies caused by the splitting of SHE and Quality issues.
Overall, we judged that relevant good practice was generally met.
Based on the evidence sampled we consider that an inspection rating of GREEN (no formal action) is appropriate for LC7.