- Site: AWE Aldermaston
- Inspection ID: 50357
- Date: July 2022
- LC numbers: 10, 12
Executive summary
Purpose of inspection
To look at the licensee's compliance with its arrangements made under LC10 (Training) and LC12 (Duly Authorised and other Suitably Qualified and Experienced Persons) in the context of its planned training design and delivery, for the role out of new maintenance and operating instructions written to support the implementation of the new Facility Safety Justification for A45 on the AWE Aldermaston site.
Subject(s) of inspection
- LC10 - Training (Rating: Green)
- LC12 - Duly authorised and other suitably qualified and experienced persons (Rating: Green)
Key findings
Executive summary
Accompanied by an ONR leadership and management for safety specialist inspector, I conducted a planned (i.e. on the AWE Integrated Intervention Strategy - IIS Plan for AWE for 2022/2023) Licence Condition (LC) 10 “Training” and LC12 (“Duly Authorised and Other Suitably Qualified and Experienced Persons”) inspection in the Uranium Technology Centre (UTC) at AWE Aldermaston. The focus was on UTC’s enriched uranium (EU) facilities, rather than its depleted uranium (DU) facilities, since the DU facilities present a lesser nuclear safety hazard.
A scope for the inspection was sent to AWE in advance of the inspection and the inspection was conducted against the guidance contained in the extant relevant ONR Technical Inspection Guides, TIG (see NS-INSP-GD-010 and NS-INSP-GD-012).
The quality of the presentations from AWE at the commencement of the inspection allowed us to concentrate on sampling of the underpinning evidence. The evidence we sampled is detailed in the main body of this report. However, from the totality of our discussions with key duty holder personnel (including a UTC safety representative) and from our sampling of various duty holder documents our judgements were:-
Positive feedback
The spreadsheet, developed by the UTC maintenance personnel to track the training/SQEP status of the electrical and mechanical maintainers in UTC was of a good quality and was well managed.
The draft OBT documents sampled were found to be of a good quality.
We were pleased to hear about initiatives in progress around the systematic approach to training, including Training Needs Analysis and provision of SQEPed trainers using ‘train the trainer’ courses etc. but again noted that these need to be taken to fruition in the nearer term.
Oversight of contractor training by AWE was judged to be adequate.
Information from the UTC safety representative indicated that training quality was considered to be of a good and that there was positive support from AWE for personnel attending external training courses.
UTC evidenced a robust process for the identification of DAP requirements and this process was demonstrably safety case led.
LC10 areas for improvement
The planned training delivery structure appeared logical and appeared to be following AWE’s arrangements in this area. However, we noted the absence of detailed plans against which UTC can measure its training delivery progress.
The UTC management team has some ideas as to how it will ensure due governance is conducted before personnel are ‘signed off’ as being Suitably Qualified and Experienced Persons, SQEP, to work in A** but it was clear that the actual detail behind the governance process is still to be developed.
The UTC safety representative we spoke to brought to our attention that for those personnel with only infrequent access to a PC (e.g. hands-on maintainers) access to their own training records was more challenging.
We noted some apparent ‘glitches’ on AWE’s MINERVA training database where we were told some training courses had no required refreshment periodicity, but yet MINERVA seemed to report a required 3 year refresh periodicity. In one case a course had a three year refresher periodicity and yet this had been set to four years on Minerva.
In the maintenance area, if a person falls out of date for any of their training requirements, then a pragmatic approach has been adopted to allow that person to continue with their work (provided they are supervised in the conduct of the work) until such time as they can take a suitable training course. Whilst we accepted that this was a pragmatic approach, we questioned whether the approach lay out with AWE’s arrangements in this area? However, consultation with AWE and sampling of AWE’s arrangements in this area indicates that provided there is a written justification in place for the maintainer continuing work in a supervised capacity (evidence was presented during our inspection that this was the case) then we consider AWE to be operating within its arrangements. However, see ‘Advice’ below.
LC12 areas for improvement
A previous ONR inspection in June 2021 (see CM9 2021/38110) noted that UTC needed to improve its DAP resilience/ succession planning but that no evidence was presented of progress against this previous advice. We also observed that DAP resilience planning across AWE is a known issue but that other AWE Technology Centres (e.g. PTC) has made adequate progress in addressing the issue.
The process for accrediting DAPs in UTC and the DAP appointment letters in UTC could be improved and the UTC management staff were advised to look at the model in PTC.
Advice to AWE
The following key advice was provided to AWE at the conclusion of the inspection i.e.
There is an urgent need for UTC to produce a fully integrated FSJ implementation plan of which training and its delivery will form a key component. UTC should then routinely monitor its progress against this plan.
The governance process for AWE assuring itself that personnel are SQEP to work in A** also needs to be developed, documented, tested, refined and implemented as a matter of urgency.
The quality of DAP assessments and appointment letters needs to be improved and it was suggested that PTC was a good model in this area.
Urgent improvements are required in UTC’s DAP succession planning and evidence is required to demonstrate progress in this area.
AWE should consider improving visibility of a ‘golden thread’ to link its written justifications, for maintainers who have gone ‘out-of-ticket’ on training continuing to conduct their duties but under supervision, to AWE’s arrangements in this area.
Overall inspection rating
From the totality of the evidence sampled we were content that a ‘Green’ adequate inspection rating was appropriate, although noting that a number of pieces of important ‘Advice’ were communicated to the duty holder (see above).
Judgements made
From the totality of the evidence sampled we were content that a 'Green' adequate inspection rating was appropriate, although noting that a number of pieces of important 'Advice' were communicated to the duty holder (see above).