The purpose of this intervention was to undertake a Licence Condition (LC) compliance inspection at Aldermaston in line with the planned inspection programme contained in the AWE Integrated Intervention Strategy and associated Intervention Plans.
The LC7 compliance inspection comprised of a desktop review of the documented arrangements and discussion with the LC7 manager to review progress since previous interventions.
I also observed the Burghfield Nuclear Licenced Site Level 3 Regulatory Interface Meeting (RIM) and the Capital Projects Level 3 RIM, from a programme assurance perspective.
Not applicable during this inspection.
Improvements have been made to address shortcomings recognised by AWE with causal codes, root cause methodology, training for event investigators and clarity of responsibilities. These improvements, although welcome, have taken longer than anticipated and are still not complete. The LC7 manager’s self-assessment regarding LC compliance is ‘yellow’, compliance issue/concern identified and he reports, on a quarterly basis, to the AWE site regulatory compliance office the additional controls applied and associated actions required to recover the situation, including introducing compliance metrics.
The arrangements made by AWE to comply with LC7 are under review and require updating to reflect changes and improvements to the internal processes, ONR provided advice on a draft issue of the standard for compliance with LC7.
Abnormal event reporting on major projects is recognised as not being at the right level. This has been known about for some time, has been identified by AWE’s internal regulation group, was identified during the ONR benchmarking inspection in May 2015 and prior to this advice has been provided to the project management team on a number of occasions. The focus continues to be on corrective actions linked to non-conformance reports with limited, if any, consideration given to prevention and learning.
An INF1 had not been raised for a recent RIDDOR reportable event, with AWE of the belief that ONR guidance did not require both a RIDDOR report and INF1. The LC7 manager was advised that an INF1 was appropriate for such a significant, albeit ‘conventional’ safety event, particularly from the learning from experience and preventing a recurrence perspective, and possible media interest. ONR reiterated previous advice that if there is any doubt, then raise an INF1.
I observed the Burghfield L3 RIM and the Capital Projects L3 RIM. Both meetings were well managed and had appropriate attendance by AWE and regulators, with the exception that at the Capital Projects meeting there was no representative from the current assembly operations team. DNSR has noted that there may be a potential disconnect between existing operations and the Mensa team with respect to capability and it needs to be taken forward in a coherent way.
The conclusion from the evidence sampled during this intervention is that fundamental requirements for LC7 are met, but there were specific procedural weaknesses identified. Improvements to the LC7 process, identified by AWE, have yet to complete and are not fully embedded. The overarching arrangements and procedures require review and update and the current compliance status defined by AWE is compliance issue/concern identified and additional controls are being applied to recover under normal controls. There is a potential for the assurance observation report process to under categorise safety related events and the number of abnormal event reports on the major projects appears low compared to the number of non-conformance reports. There appeared to be a lack of awareness by AWE of the potential learning opportunities from raising an INF1 at the time of a recent significant ‘conventional’ safety event. Shortfalls against LC7 are being progressed with AWE as a regulatory issue.