Health and Safety
Executive / Commission
Nuclear
LLC reports
This report is issued as part of the Health and Safety Executive's commitment to make information about inspection and regulatory activities relating to the above site available to the public. It is for distribution to members of the Barrow-in-Furness Local Liaison committee (LLC) and covers activities associated with the regulation of nuclear safety at BAE SYSTEMS Marine Limited (BAESM). These reports are distributed quarterly.
Site Inspectors of HM Nuclear Installations Inspectorate normally attend LLC meetings and will be happy to respond to questions raised there or subsequently by members of the LLC. Any other person wishing to inquire about matters covered by this report should contact the HSE, Nuclear Directorate on 0151 951 3484/3290.
This report will be put onto the HSE Website at www.hse.gov.uk/nuclear/llc/index.htm.
The majority of sites inspected by HM Nuclear Installations Inspectorate (NII), a part of the Health and Safety Executive, are licensed by NII under the Nuclear Installations Act 1965 (as amended). This report summarises the inspection and regulatory activities associated with the Barrow-in-Furness licensed site. In accordance with the HSE commitments to open government, this report will also be placed on the HSE Website.
Visits are made to the site for the purpose of undertaking routine plant and project inspections or attending formal meetings with site management or safety representatives. Routine inspections by NII are undertaken primarily to check compliance with licence conditions made under the Nuclear Installations Act, but are also made against provisions of the Health & Safety at Work Act 1974, and regulations made under that Act such as the Ionising Radiations Regulations 1999. The site inspector visited site on:
Matters covered in this section are those being pursued with the site as part of ongoing site inspection activity and dialogue including project work and any generic or topical work relevant to all licensees.
As part of the routine inspection programme for the site, NII inspectors check compliance with licence conditions made under the Nuclear Installations Act and other regulations such as the Ionising Radiation Regulations 1999.
Inspectors from NII and the Defence Nuclear Safety Regulator jointly inspected BAE’s operational readiness for regulatory release of Astute Hold Point 3.C, which allows the delivery and acceptance of nuclear fuel onto the Barrow Site and reactor core build in the New Core Facility. The regulatory team concluded that BAE was organisationally and administratively ready, and regulatory agreement was granted for release of the hold point.
Following discussions concerning compliance with the Radiation (Emergency Preparedness and Public Information) Regulations, BAE has been asked to convene an early meeting with NII and DNSR to discuss the safety case for reactor critical and post-critical activities on the licensed site. BAE has been asked to present the intended structure of the safety case concentrating on how it aims to demonstrate that risks are tolerable and ALARP and whether a radiation emergency is reasonably foreseeable. BAE has been asked to identify any threats to achieving this aim so that an appropriate, proactive intervention strategy can be developed.
A joint NII / DNSR inspection of BAE’s compliance with Licence Condition 7, Incidents on the Site, found the company had good business processes for event capture and investigation, but those for the analysis of and feedback from events needed to be developed and improved. The regulators advised the Company that it should compare its arrangements with current international guidance so as to identify areas for improvement and to report its findings, together with proposals for implementation, to NII and DNSR in December 2006.
Matters involving NII’s response to incidents/events and to non-routine issues arising from operation of the site are covered in this section together with the outcome of any special/team inspections, investigations or audits.
The site intervention plan for Barrow has been revised following a number of events on site involving failures to control work to the expected standards. Under the revised plan, NII and DNSR will undertake intervention activity focused on BAE introducing appropriate, short-term measures to compensate for the current weaknesses in the control of work systems while monitoring and encouraging BAE’s progress in implementing permanent improvements. It is anticipated the longer-term activity will be aimed at remedying systemic weaknesses in management systems, safety culture and inappropriate behaviours, which have been identified by BAE as contributory and underlying causes of the events.
HMNII issues formal regulatory documents called licence instruments where these are called for under conditions attached to the nuclear site licence. Regulatory responsibility for authorising discharges and disposal of radioactive wastes from the sites lies with the Environment Agency.
The following regulatory document was issued by NII for the Barrow site on 9 October 2006:
Licence Instrument No. 503: Agreement to Release the Astute Phase 3.C Hold Point.