- Site: AWE Aldermaston and AWE Burghfield
- IR number: 21-095
- Date: October 2021
- LC numbers: 17
Executive summary
Purpose of intervention
The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Atomic Weapons Establishment (AWE) against a strategy defined by the ONR Weapons Sub-Division. This intervention relates to Licence Condition 17 (LC17), which requires a Licensee to make and implement a management system that gives due priority to safety. A fundamental element of these arrangements is the management of a Licensee’s processes that are important to safety.
The purpose of this inspection was to test the adequacy of two of AWE’s processes used to manage safety.
In accordance with the strategy and the requirements of LC17, a management systems inspection was carried out between the 6th and 7th October 2021.
Interventions Carried Out by ONR
The inspection determined the adequacy of two of AWE’s LC 17 processes, used to manage:
- Planning, governance and assurance arrangements for delivery of regulatory commitments (regulatory submissions and regulatory issues) across AWE’s Aldermaston and Burghfield sites.
- Internal assurance, challenge and the provision of nuclear safety advice at its Burghfield site.
These two processes were measured against ONR’s regulatory expectations, informed by relevant good practice and ONR guidance documentation. Regulatory expectations for the management of these two processes are recorded in:
- NS-INSP-GD-017 - LC 17- Management Systems.
- ONR Safety Assessment Principles for Nuclear Facilities - 2014 Edition, Revision 1 (January 2020) – Leadership and Management for Safety (Leadership, Capable Organisation, Decision Making, Learning).
- NS-TAST-GD-080 - Challenge Culture, Independent Challenge Capability (including an Internal Regulation function) and the provision of Nuclear Safety Advice.
This inspection was rated based on the ONR inspection rating system guidance as explained in ONR-INSP-GD – 064 - ONR ‘Compliance Inspection Guide’. This is available on the ONR external website.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
Planning, governance and assurance arrangements for delivery of regulatory commitments (regulatory submissions and regulatory issues) across AWE’s Aldermaston and Burghfield sites
Good points
- AWE had a good understanding of its process to manage its regulatory commitments with this process acting as its one source of up-to-date regulatory information.
- The AWE Project Management Office (PMO) team responsible for managing its regulatory commitments, appeared to be well integrated, working as one team.
- Significant improvements were made in the management of its regulatory commitments.
Minor observations
- There was a lack of evidence to demonstrate how it gave due regard for safety when prioritising submissions.
- The lack of AWE’s PMO management arrangement documentation to fully represent the current arrangements the PMO implements.
- The appropriateness for its strategy papers (i.e. overarching Asset Change Request) to be subject to formal regulatory hold points when they only provided a project delivery narrative.
- The lack of the transmission of the learning from an incident, (where work had commenced in advance of receiving the regulatory permission), to other applicable licence condition arrangements.
- The PMO’s lack of formal monitoring of its regulatory issues escalated for a higher level of scrutiny.
- Internal assurance, challenge and the provision of nuclear safety advice at its Burghfield site
Good points
- Clear leadership direction and example were set by the AWE Plc Board and Executive Committee on AWE’s expectations for the management of internal challenge and assurance.
- Clear arrangements for the application of internal challenge and assurance principles were evidenced across the business.
- There was clarity of the independence of Internal Regulation from other AWE processes, with clear lines for reporting and escalation.
Minor observations
- AWE to consider the sufficiency of its current internal regulation resource to provide adequate oversight for future capital projects.
- AWE to consider the robustness of its arrangements to address the management and closure of findings from the surveillance arm of its internal regulation.
Conclusion of Intervention
Based on ONR’s findings from the evidence sampled, I judge that AWE has adequate LC 17 arrangements to manage:
- Planning, governance and assurance arrangements for delivery of regulatory commitments (regulatory submissions and regulatory issues) across AWE’s Aldermaston and Burghfield sites.
- Internal assurance, challenge and the provision of nuclear safety advice at its Burghfield site.
Taking the above into account I consider that an inspection rating of Green (No Formal Action) is merited for the said AWE LC17 management arrangements, noting the relevant guidance within ONR documentation.