- Site: AWE Aldermaston
- IR number: 21-075
- Date: September 2021
- LC numbers: 35
Executive summary
Purpose of Intervention
The Office for Nuclear Regulation (ONR) undertakes all regulatory interactions with the Aldermaston site licensee (AWE plc) against a strategy defined by the ONR Weapons sub-Division. In accordance with that strategy, a planned Licence Condition (LC) 35 (Decommissioning) compliance inspection was carried out in the Waste and Decommissioning area in September 2021. The purpose of this inspection was for ONR to determine the adequacy of the implementation of the licensee’s formal arrangements for compliance with LC 35 (Decommissioning).
This intervention will also inform the ONR Chief Nuclear Inspector’s themed inspection on ‘Ageing Management’.
Interventions Carried Out by ONR
On 21 and 22 September 2021, I, along with the Site Inspector for the Waste, Decommissioning and Transport Technical Centre (WD&T TC), carried out a LC 35 compliance inspection at the Aldermaston site. The inspection comprised, desk-top based discussions, review of documentation and a plant inspection.
The primary requirements of LC 35 are for the licensee to make and implement adequate arrangements for the decommissioning of any plant that may affect safety, and to make arrangements for the production and implementation of decommissioning programmes for each plant.
The inspection was conducted in accordance with the following relevant ONR guidance document for this licence condition:
- NS-INSP-GD-035 Revision 6, April 2019
- NS-TAST-GD-026 Revision 5, September 2019.
Explanation of Judgement if Safety System Not Judged to be Adequate
This was not a system based inspection.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
On the basis of the evidence sampled, I found a number of shortfalls in relation to the following aspects:
- AWE has not adequately implemented its arrangements for decommissioning and has fallen short of ONR’s expectations for prompt decommissioning; this is because AWE has not delivered an adequate safety case for high-hazard decommissioning in a timely manner
- AWE could not demonstrate effective governance arrangements for the decommissioning programme. Specifically, it was not clear how progress and performance shortfalls were reported to the Executive to enable them to ensure that adequate financial and human resources are made available to support the decommissioning programme priorities
- AWE has not adequately identified the consequences of failure of key civil structures in the hazard sequence within the current safety cases in the WD&T TC. This has led to shortfalls in the Asset Management System, as civil structures have not been subject to adequate surveillance
- AWE could not adequately demonstrate how knowledge relevant to future decommissioning activities is identified and managed during a facility’s lifecycle. This has implications on the safety of operations during decommissioning
- AWE was not able to provide a SQEP assessment for the Technical Owner (Tier 2 LC 35 Owner).
I have therefore proposed a Regulatory Issue to track the licensee’s progress in addressing these shortfalls.
Conclusion of Intervention
I consider that, on the basis of evidence sampled at the time of this inspection, the licensee has not adequately implemented its arrangements for compliance with LC 35 (Decommissioning). I consider that an inspection rating of Amber is merited.