Executive summary
Date(s) of inspection: September 2024
Aim of inspection
This planned inspection sampled the implementation of a change to safety governance and permissioning arrangements for AWE to inform Office for Nuclear Regulation's (ONR) judgement on the improvements that the licensee claimed to have implemented. This is not a compliance inspection. The intervention is in accordance with the Office for Nuclear Regulation (ONR) 2024/2025 Regulatory Strategy, namely KRO 1 "AWE (A) delivers the improvements necessary to demonstrate sustained adequate performance and capability to return to a routine level of regulatory attention", and supports DRO 1.1 "Corporate governance arrangements demonstrate appropriate decision making at all levels".
Subject(s) of inspection
- Leadership & Management for Safety - Rating: Not rated
Key findings, inspector's opinions and reasons for judgement made
This planned inspection sampled the implementation of a change to safety governance and permissioning arrangements for AWE to inform Office for Nuclear Regulation's (ONR) judgement on the improvements that the licensee claimed to have implemented. This is an unrated compliance inspection. The intervention is in accordance with the Office for Nuclear Regulation (ONR) 2024/2025 Regulatory Strategy, namely KRO 1 "AWE (A) delivers the improvements necessary to demonstrate sustained adequate performance and capability to return to a routine level of regulatory attention", and supports DRO 1.1 "Corporate governance arrangements demonstrate appropriate decision making at all levels".
The aim of the inspection was to consider the governance changes namely the introduction of Local Management Safety Committees (LMSCs), and the revised composition of the Nuclear Safety Committee (NSC) to verify that the changes had not degraded the efficacy of governance around safety submissions. As part of the inspection two LMSCs were observed, as well as the NSC. Discussions were also had with a range of role holders involved in safety governance to sample their views of the effectiveness of these changes, consistency, purpose, alignment, adequacy, learning and threats.
Overall, I judge that relevant good practice was met in the sample , with some areas of good practice and some areas that AWE should consider strengthening.
The aim of the inspection was to consider the governance changes namely the introduction of Local Management Safety Committees (LMSCs), and the revised composition of the Nuclear Safety Committee (NSC) to verify that the changes had not degraded the efficacy of governance around safety submissions. As part of the inspection two LMSCs were observed, as well as the NSC. Discussions were also had with a range of role holders involved in safety governance to sample their views of the effectiveness of these changes, consistency, purpose, alignment, adequacy, learning and threats.
Overall, I judge that relevant good practice was met in the sample , with some areas of good practice and some areas that AWE should consider strengthening.
- The intent of the change had been to improve the quality of safety submissions. It was reflected by AWE that this has not been consistently attained yet, and that further work is required.
- The Community of Practice (CoP) was recognised as a useful forum for LMSC chairs and deputy chairs to ensure consistency across the LMSCs, as well as identify opportunities for improvement. This meeting was acknowledged as useful and important from those interviewed.
- There is variable workload across the LMSCs which is affecting the consistency and adequacy of these meetings. AWE is aware and is considering different options for improving.
- Improved governance at LMSC is highlighting shortfalls in governance at Asset Change Boards (ACB). AWE is aware and the LC22 lead is reviewing how to improve. The Internal Regulator recognises this and is going to carry out an activity to investigate the shortfall.
- Determine appropriate governance routes for Management of Organisational Change proposals (1536). Currently no equivalent of LMSC is available for these types of submissions.
- During the NSC sampled there were a couple of occasions where NSC members queried the accuracy of data and material in a submission, rather than reflecting on the broader case or the implications of their understanding of data differing from the case. I would recommend the NSC chair consider how to address this, to ensure that the 'bigger' picture is not lost by data accuracy concerns.
Conclusion
I judge that AWE’s revised governance arrangements sampled during this inspection are meeting the expectations for the conduct of Nuclear Safety Committees. The inspection identified alignment with Principles 4 and 6 of NS-INSP-GD-013. Implementation of these changes with respect to safety submissions have been inspected and based on my sample are judged to have improved the governance around safety to an adequate level.