Office for Nuclear Regulation

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LC36 and LC13 Inspection at AWE

Executive summary

Purpose of intervention

This report covers the planned LC36 enhanced inspection and LC13 Inspection at both AWE Licensed Sites undertaken in accordance with ONR’s Integrated Intervention Strategy (IIS) for the Atomic Weapons Establishment Programme.

The inspections undertaken at the AWE Licensed Site form part of a series of planned interventions in accordance with the IIS and Integrated Intervention Plan (IIP).

Interventions Carried Out by ONR

The intervention was performed in line with ONR’s guidance requirements (as described in our technical inspection guides) in the areas inspected.

ONR conducted a planned enhanced inspection of the Licence Condition (LC) 36 Organisational Capability with the AWE Internal Regulator. The inspection inspected Organisational capability at a corporate, facility, sub-programme and directorate level.

ONR also conducted a planned LC13 inspection against the requirements of LC13(10) which requires the licensee to notify ONR if Nuclear Safety Committee (NSC) advice is not followed.

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A.

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

It is the inspectors’ opinion that the LC36 arrangements have been improved, but still have some gaps against ONR and national guidance. It is also our opinion that the change in arrangements is not being adequately controlled and additional resources and governance arrangements are required to ensure adequate implementation.

The inspection found that the implementation of the existing arrangements at Assembly and within Engineering were of a higher standard to elsewhere. These areas appear to have been proactive in developing local arrangements to address shortfalls in the previous corporate LC36 arrangements.

The inspection concluded that the organisational changes sampled to date did not provide an adequate description of the changes, an adequate assessment of the risks arising from the changes and did not describe adequate arrangements for controlling or monitoring the changes. In addition, we identified other changes with the potential to impact on nuclear safety that had not been assessed through the LC36 system, including contractorisation of nuclear maintenance in a decommissioining A1 facility in 2010 and the introduction of a new Job Architecture.

The LC13 inspection concluded that the documented arrangements in place did not provide suitable assurance that, if NSC advice was not followed, the licensee would be aware of this and notify ONR. In particular, there were no documented arrangements for  passing on of NSC advice on changes made under LC36, Organisational capability.

Conclusion of Intervention

The conclusion of the LC 36 enhanced inspection is  that the shortfalls constitute a ‘Major non-compliance with defined or established standards necessary to ensure safety or security’ and thus under the ONR system would be rated as a ‘red’. Regulatory issues have been raised for the licensee to address the shortfalls and the findings of the inspection will be reviewed through the Enforcement Management Model to determine if enforcement action is appropriate.

The conclusion of the LC 13 inspection was that the process for determining whether NSC advice is followed is inadequate. ONR judge that this constitutes ‘Deficient arrangements for compliance with legal requirements’, which results in a rating of’ amber’ for this inspection. An issue has been raised to put suitable arrangements in place.