Executive summary
Date(s) of inspection: February 2025
Aim of inspection
In the face of a demanding production challenge, and delays to project performance, innovative decisions are being made (and sometimes reversed, or not used) at a rapid pace, so as to optimise the overall programme. There is a risk that the pace and scope of the decisions impacts safety through ‘ill-conceived or poorly executed’ changes. The aim of the inspection is to gain regulatory confidence that BAESML has implemented adequate arrangements for governance, assurance and internal challenge to support decisions that may affect nuclear safety.
Subject(s) of inspection
- LC13 - Nuclear safety committee - Rating: Green
- Leadership & Management for Safety - Rating: Not rated
Key findings, inspector's opinions and reasons for judgement made
The Office for Nuclear Regulation (ONR) undertakes all regulatory interventions with the BAESML nuclear site licensee, against a strategy defined by the ONR Propulsion Sub-Directorate. In accordance with that strategy, a themed Decision Making inspection was undertaken at Barrow on 18th February.
This intervention was carried out by sampling and examining the written arrangements that BAESML has in place in relation to governance, assurance and internal challenge against relevant good practice and decision making (for example LC 13 Nuclear Safety Committee and other business management arrangements) and by sampling examples of these with those responsible for implementing the arrangements. Its purpose was to gain assurance that BAESML has implemented adequate arrangements for governance, assurance and internal challenge to support decisions that may affect nuclear safety.
Overall, I found that there is a governance and assurance framework in place, and I judged it to be implemented adequately. Additionally, the licensee presented a number of credible examples showing how nuclear safety is being considered in decision making throughout the organisation, from release of hold points, operational decision making and the Nuclear Safety Committee. The inspection provided regulatory confidence that nuclear safety is maintained through robust tactical and strategic decision making, with assurance and governance arrangements providing appropriate challenge. ONR welcomed recent initiatives developed and implemented at BAESML and will seek opportunities to sample their sustained implementation during business-as-usual activities. The inspection was undertaken and considered against published guidance in NS-INSP-GD-013, 017, NS-TAST-GD-80 and our Leadership and Management for Safety (LMfS) Safety Assessment Principles (SAPs). Based on the evidence sampled at the time of the intervention I judge that BAESML demonstrated adequate compliance and alignment with regulatory guidance.
In accordance with ONR’s arrangements, I consider a rating of Green for the Nuclear Safety Committee (no formal action) appropriate for this inspection.
Conclusion
Overall, I judge that relevant good practice was met in the sample inspected with some areas of good practice and some areas that BAESML should consider strengthening. The governance and assurance arrangements as described by BAESML align with recommended good practice, and I consider them a robust framework for ensuring that nuclear safety is appropriately considered. Similarly, it described the process for senior level ownership of Licence Conditions, and, the activities undertaken to improve arrangements and their implementation appear effective. The intervention provided ONR with confidence that its independent nuclear assurance fulfilled an adequate independent challenge function and provided oversight of nuclear safety leadership, management and decision making at all levels of the organisation. The evidence sampled on the Nuclear Safety Committee show that it fulfils the intended purpose of LC13 and ONR welcomes BAESML's initiatives to continue to improve its performance. The evidence sampled around tactical decision making showed that BAESML has implemented robust arrangements, and that there is collation of evidence and challenge of adequacy ahead of release of internal hold points. BAESML recognise a number of threats going forward, and ONR will continue to monitor these activities. ONR welcome the changes recently implemented to enhance decision making within the Commissioning and Testing groups, and ONR fed back that reinforcement and encouragement would help embed these processes. BAESML acknowledged that it had been hard to embed the process as there was a reluctance by lower levels of the organisation to accept responsibility and accountability.
The inspection provided regulatory confidence that nuclear safety is maintained through robust tactical and strategic decision making, with assurance and governance arrangements providing a challenge culture, an independent challenge capability, and provision of nuclear safety advice. ONR welcomed recent initiatives developed and implemented at BAESML and will seek opportunities to sample their sustained implementation during business-as-usual activities. The inspection was undertaken and considered against published guidance in NS-INSP-GD-013, 017, NS-TAST-GD-80 and the LMfS SAPs. Based on the evidence sampled at the time of the intervention I judge that BAESML demonstrated adequate compliance and alignment with regulatory guidance. Challenges were identified in terms of safety culture and BAESML is taking actions to improve this.
In accordance with ONR’s arrangements, I consider a rating of Green for the Nuclear Safety Committee (no formal action) appropriate for this inspection.