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LC36 Compliance Inspection

  • Site: AWE Aldermaston
  • IR number: 21-096
  • Date: October 2021
  • LC numbers: 36

Executive summary

Purpose of intervention

This intervention was held at AWE, Aldermaston. The purpose was to judge AWE’s progress towards meeting the requirements of LC36 improvement notices ONR-IN-19-002 and ONR-IN-19-003.

This intervention is part of the Weapons Sub-division intervention strategy. Representatives from DNSR and AWE’s Internal Regulator have a standing invitation to join ONR inspections. As such W Townsend (DNSR) and S Bailey (AWE) were part of the inspection team.

Interventions Carried Out by ONR

This inspection was carried out on 19th and 20th October 2021. Prior to the inspection ONR had observed related AWE internal assurance and challenge activities.

The inspection was informed by the following ONR guidance documents:

  • NS-TAST-GD-065 Revision 4, Function and Content of the Nuclear Baseline
  • NS-TAST-GD-048 Revision 6, Organisational Change

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A. This was not a systems-based inspection.

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

I examined AWE’s planned progress towards meeting the requirements of the LC36 improvement notices. My sampling focused on:

  • Development and maintenance of the nuclear baseline.
  • Management of vulnerabilities on the nuclear baseline.
  • Management of changes to the nuclear baseline.
  • Related internal assurance and governance.

AWE provided clear evidence of progress against plans. However, I judge that there are shortfalls in AWE fully meeting the requirements of the improvement notices. In summary:

  • Development of the nuclear baseline is not yet complete.
  • There was some evidence of lack of maintenance of the nuclear baseline.
  • As a consequence of the nuclear baseline not yet being complete, vulnerability management is still maturing. However, I judge that AWE provided evidence of good practice in vulnerability management for some of the areas sampled.
  • A further consequence of the nuclear baseline not being fully complete is that all nuclear safety related roles may not be included in management of change assessments.
  • I judge that categorisation of changes to the nuclear baseline needs further clarity.
  • Further evidence of implementation of higher categorised changes is still required.
  • My sampling provided clear evidence of internal assurance and challenge. However, there was also evidence that AWE’s response to internal assurance and challenge is not supported by credible plans.

Conclusion of Intervention

I judge that this inspection is rated amber which requires me to seek further improvement.

I consider that while significant progress has been made by AWE the requirements of the LC36 improvement notices have not been fully met, and I consider that this is unlikely to change by the due date of 17 December 2021.

However, due to the progress made and the improvement plans already in place and being delivered by AWE, I judge that extending the notices for a second time would be disproportionate and that the remaining improvements can be secured by more targeted and proportionate enforcement.

The regulatory strategy to support the remaining improvements is informed by the Enforcement Management Model and will be further informed by AWE’s response to this inspection and a further targeted inspection planned for January 2022.

AWE’s progress will be reviewed monthly by ONR until all shortfalls are closed.