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Compliance with meeting the requirements of LC36 Improvement Notices

  • Site: AWE Aldermaston
  • IR number: 21-145
  • Date: January 2022
  • 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 (Organisational capability) improvement notices ONR-IN-19-002 and ONR-IN-19-003, and to determine any further enforcement as we were already aware that the requirements of the notices would not be fully met by the due date.

This intervention is part of the Weapons Sub-division intervention strategy. It was originally planned to check AWE’s compliance with meeting the requirements of the LC36 improvement notices following the due date (17 December 2021). During a pre-inspection in October 2021, ONR judged that the requirements of the LC36 improvement notices would not be met by the due date. Consequently, this inspection was re-purposed to inspect AWE’s progress since October 2021.

Representatives from the Defence Nuclear Safety Regulator (DNSR) and AWE’s Internal Regulator have a standing invitation to join ONR inspections. As such representatives from DNSR and AWE were part of the inspection team.

Interventions Carried Out by ONR

This inspection was carried out on 26th January 2022. Prior to the inspection I had reviewed AWE’s LC36 arrangements and the AWE LC36 improvement plan.

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:

  • The quality of the LC36 plan proposed by AWE to close the shortfalls in meeting the requirements of the improvement notices.
  • AWE’s progress against the LC36 plan.
  • An inspection of AWE’s revised LC36 arrangements.

AWE provided clear evidence that an adequate LC36 improvement plan has been developed, that the plan has adequate governance and that delivery is progressing. In summary:

  • Development of the nuclear baseline has progressed since the last LC36 inspection and there is evidence of improved guidance. I judge that definition of roles on the nuclear baseline requires further clarity and consequently the nuclear baseline is still maturing. However, I judge that adequate progress has been made since the last LC36 inspection. 
  • Vulnerability management was sampled for the maintenance function. I judge that AWE did not provide adequate evidence of vulnerability management for the area sampled. A targeted regulatory issue will be raised.
  • I sampled AWE’s management of change for 4 changes. I judge that AWE provided adequate evidence of management of change for all areas sampled.

I sampled AWE’s LC36 arrangements and found that some aspects of the arrangements need further improvement. I noted that AWE had also identified areas for improvement prior to the inspection. I also noted that AWE was following advice from its Nuclear Safety Committee to monitor implementation of the arrangements for a period of 6 months before incorporating further improvements. I judge this to be an adequate approach.

I considered any enforcement necessary due to the full requirements of the improvements notices not being met by the due date. I judge that a regulatory advice letter is proportionate enforcement.

Conclusion of Intervention

I judge that AWE’s LC36 improvement plan is now adequate and I note that AWE demonstrated evidence of progress against the plan in most of the areas sampled.

I judge that there was inadequate evidence of progress on vulnerability management for the maintenance function.

I judge that this inspection is rated amber which requires me to seek further improvement. Consequently, a level 3 regulatory issue will be raised to seek improvement on vulnerability management.

I judge that proportionate enforcement to secure delivery of the remaining improvements will be a regulatory advice letter.