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Review of AWE's progress against action 3 of L1 Issue 7493, “AWE’s move to routine regulatory attention”

  • Site: AWE
  • IR number: 20-050
  • Date: October 2020
  • LC numbers: N/A

Executive summary

Purpose of Intervention

The Office for Nuclear Regulation [ONR] undertakes all regulatory interaction at AWE plc against a strategy defined by the ONR Weapons sub-Division. In accordance with that strategy, a review of AWE’s progress against action 3 of the level 1 regulatory issue “AWE’s move to routine regulatory attention” was carried out as planned during September/October 2020. Action 3 of the regulatory issue asks the licensee to provide evidence of delivery of an adequate strategic holistic approach aimed at achieving and sustaining compliance.

The review covered the Aldermaston and Burghfield licenced sites. The outcome will inform the ONR annual assignment of dutyholder attention levels.

Interventions Carried Out by ONR

The review was informed by ONR’s published guidance:

and the Infrastructure and Projects Authority guidance:

This was not a compliance inspection and therefore no rating was given in line with the ONR Inspection Ratings Guide.

Explanation of Judgement if Safety System Not Judged to be Adequate

This was not a system based inspection and therefore no judgement has been made of the adequacy of implementation of any part of the safety case.

Key Findings, Inspector's Opinions and Reasons for Judgements Made

During my inspection, I sampled evidence to determine the adequacy of the licensee’s approach, governance and assurance for delivery of the safety improvement programme that it has established and is implementing to support a move to routine regulatory attention.

Due to COVID-19 restrictions evidence for this intervention was primarily obtained by remote observation of the licensee’s internal meetings. Follow up interventions for clarification purposes were arranged as required.

This intervention considered AWE plc’s approach, governance and assurance as the licence holder for both licensed sites, Aldermaston and Burghfield.

On the basis of the sample that I reviewed, there is evidence that progress has been made towards a move to routine regulatory attention, but the licensee has not yet demonstrated enough progress to be considered for a reduction in the level of regulatory attention. I acknowledge that the safety improvement programme is long term and wide ranging. Consequently recommendation of a reduction in the licensee’s level of regulatory attention was not expected at this time.

Notable improvements include:

  • The change in CEO leadership during 2020 has resulted in a better demonstration of the licensee’s commitment to deliver safety improvements and improve safety culture. Although the new leadership is at an early stage, the change gives increased confidence of the potential for AWE plc to move to routine regulatory attention.
  • The programme of improvements has clearly documented control arrangements which set out the required governance and there is demonstrable evidence that AWE plc is following recognised good practice in terms of programme development and delivery thinking.
  • Clear evidence of a professional approach was observed from the Nuclear Safety Committee for the provision of advice and internal challenge to the licensee, and a professional approach was also observed from those receiving the advice and internal challenge in the areas sampled.
  • There is evidence that the new Technical Oversight Panel has the potential to positively contribute to the timely delivery of adequate safety documentation. This relatively new panel demonstrated a structured approach with a good balance between offering advice and giving internal challenge.

While there is evidence that a number of safety improvements are progressing in line with regulatory expectations, the licensee should provide increased focus on areas which are less mature including:   

  • Further developing the holistic, autonomous approach to include all safety initiatives, with clearly defined safety outcomes and benefits.
  • Demonstrating an adequate pace for delivering safety outcomes and benefits to support a timely move to routine regulatory attention.
  • Improving consistency of adequate internal challenge at all leadership levels to support demonstration of autonomy.
  • Further developing suitable safety performance indicators to be less subjective, in support of effective delivery of safety improvement, oversight of safety performance and decision making.
  • Further development of risk informed holistic integrated planning, resourcing and prioritisation, focused on providing confidence in sustainable delivery of regulatory commitments.
  • Embedding learning from experience to support reduction in repeat events.

I commend the licensee’s open and honest approach during this review.

Conclusion of Intervention

Based on the evidence sampled, I judge that AWE plc has demonstrated progress towards a move to routine regulatory attention.

The integrated programme for delivery of regulatory commitments, although at an advanced stage, still requires further development to increase confidence on when a reduction in regulatory attention levels can be considered. I acknowledge that the licensee has planned this further development and I judge that the plans have the potential to achieve the outcome.

Evidence of achieving and sustaining safety performance is insufficient at this time to recommend a reduction in regulatory attention. I acknowledge that the safety improvement programme is long term and wide ranging. Consequently recommendation of a reduction in the licensee’s level of regulatory attention at this time was not expected.

No new regulatory issues have been raised however I recommend that AWE plc review the actions in the extant level 1 regulatory issue and propose new actions in line with the findings in this report.