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Foreword

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 Local Liaison Committee and covers activities associated with the regulation of safety at the Devonshire Dock Complex, Barrow-in-Furness.  These reports are distributed quarterly and are also available on the HSE’s web site at http://www.hse.gov.uk/nuclear/llc/index.htm

Site Inspectors of HM Nuclear Installations Inspectorate usually attend LLC meetings and will respond to questions raised there by members of the LLC.  

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Inspections

The Nuclear Installations Inspectorate (NII) Site Inspector made inspections on the following dates during the quarter:

• 8th, 20th and 21st October
• 16th to 18th and 30th November
• 1st and 14th to 16th December.

NII’s Deputy Chief Inspector for Defence Facilities Regulation visited the site on 1st December.
NII’s Superintending Inspector for the Naval Nuclear Propulsion Programme Inspection Unit attended the site on 1st, 13th and 14th December. 

Other NII specialist inspectors visited the site on 8th, 20th and 21st October, 16th to 18th and 30th November and 1st and 13th to 16th December.

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Routine matters

Inspections are undertaken at site as part of the process for monitoring compliance with:

1. the conditions attached by HSE/NII to the nuclear site licence;
   
2. the Health and Safety at Work etc Act (HSWA) 1974; and
   
3. regulations made under the HSWA for example the Ionising Radiations Regulations 1999 and the Management of Health and Safety at Work Regulations 1999.

This entails monitoring licensee’s actions on the site in relation to incidents, operations, maintenance, projects, modifications, safety case changes and any other matters which may affect safety.  The licensees/operators are required to make and implement adequate arrangements under the conditions attached to the licence in order to ensure legal compliance.  Inspections seek to judge both the adequacy of these arrangements and their implementation.  In this period inspections at the Devonshire Dock Complex covered:

• Radiological protection.
• Incidents on the Site.
• Staff training, qualifications and experience.
• Emergency preparedness.
• Quality Assurance and records.
• Plant construction and commissioning.
• Examination, Maintenance, Inspection and Testing.
• Management of operations including control and supervision.
• Organisational Changes.
• Periodic safety review.
• Meeting Safety Reps.

In general the arrangements made and implemented by BAE SYSTEMS Marine Ltd (BAE) in response to safety requirements were deemed to be adequate in the areas inspected.  However, where improvements were considered necessary, satisfactory commitments to address the issues were made by or are being sought from the licensee, and the site inspector will monitor progress during future visits.  Where necessary, formal regulatory enforcement action will be taken to ensure that appropriate remedial measures are implemented to reasonably practicable timescales.

As noted in the Quarter 3 LLC report, NII and DNSR required that a further demonstration exercise be carried out once the emergency arrangements had been improved to reflect the lessons from INDIGO 2010, which took place in July.  This demonstration emergency exercise took place on 14th December and it was clear that much effort had been put into addressing the concerns from the July exercise and improving the arrangements and their implementation.  NII and DNSR considered that the emergency arrangements had been adequately demonstrated.

Specialist NII Inspectors presented the rationale and approach of the NII’s strategy Leadership and Management for Safety to both the BAE Systems Submarine Solutions Board and subsequently to a large group of senior managers.  Our Specialist Inspectors explained how organisational and cultural shortcomings are identified consistently as underlying causes of major accidents and events around the world in nuclear and other industries whatever the regulatory regime. The organisational and cultural issues are often complex but a number of common factors have been identified from event investigations and research studies. These include ineffective leadership, inadequate management oversight and scrutiny of safety, poor decision making and lack of effective challenge and failure to apply lessons from within and outside the organisation.  This has led most nuclear regulators to recognise the need to consider organisational and cultural issues as part of their regulatory activities and this has resulted in NII’s Leadership and Management for Safety strategy, which includes recognition of the need for increased focus on Board/Director/Senior Management levels within organisations due to their strong influence on culture and safety.

Discussions were held with the site’s Operational Experience Feedback (OEF) team to get an update on progress over recent months.  The team are working on developing communications on learning from significant incidents/events on site to ensure that lessons are promulgated within the business.  They have been instrumental in getting company procedures amended to take account of learning and prevent recurrence.  Regulators were pleased to note the senior management support that is being provided in this important area.

Improvements to the site’s processes for control of organisational change have continued throughout the year to the point where certain of the revised processes are now recognised as being best practice and it has been recommended that BAE presents these to the wider nuclear industry through the Safety Directors Forum Industry Working Group on Organisational Capability.  During November, NII permissioned changes to the part of BAE that commissions submarine systems, the Dockside Test Organisation.  This followed extensive discussions on the revised organisational structure and the risks to nuclear safety of the change and we were satisfied that the risks have been properly mitigated and will be monitored whilst the change is implemented.  A summary of the reasoning for allowing this change to proceed is available on our web site.

An inspection was carried out with DNSR of the site’s arrangements for control of documents and records.  The inspection found the arrangements to fall considerably short of expectations.  The record management arrangements lack a strategic approach and each work area appears to be managing and keeping its records in isolation.  This situation is compounded by record schedules which are inaccurate and incomplete.  The inspection team made a number of recommendations for improving the records management arrangements.  In mitigation, the sampled work areas on site were diligently keeping records and the personnel were very protective of them.  From the plethora of information seen during the inspection it is considered that BAE have retained most, if not all, documentation generated over the years they have been operating.

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Non-routine matters

Licensees are required to have arrangements to respond to non-routine matters and events.  NII inspectors judge the adequacy of the licensee’s/operators response including actions taken to implement any necessary improvements.  There were no items of particular note during the reporting period.

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Regulatory activity

Under Health and Safety legislation NII Site Inspectors, and other HSE Inspectors, may issue formal documents to ensure compliance with regulatory requirements.  Under nuclear site licence conditions HSE/NII issues regulatory documents, which either permission an activity or requires some form of action to be taken; these are collectively termed Licence Instruments.  In addition inspectors may issue enforcement notices to secure improvements to safety.  No enforcement notices or Licence Instruments were issued to the licensee during the quarter.

Transforming Our Business

HSE’s Nuclear Directorate (ND) continues work on a programme of change entitled 'Transformation' which is intended to help ND realise its aims to become recognised as a world-class regulator. Over the coming months, ND’s focus will include improving the way it engages with all of its stakeholders, including communities around nuclear licensed sites, to explain the work that it does and the regulatory decisions it makes.

ND will keep stakeholders fully informed of changes and any decisions that are made through channels including:

• The HSE Nuclear eBulletin (visit www.hse.gov.uk/nuclear/ebulletin to subscribe);
• Site stakeholder group and local liaison committee reports;
• ND's newly re-launched website (www.hse.gov.uk/nuclear).

If you have any comments, questions or suggestions regarding ND’s Transformation programme, please get in touch by emailing ONRenquiries@hse.gsi.gov.uk.

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