Office for Nuclear Regulation

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System Based Inspection (SBI) - Radiography - In the Main AWE (A) Production Facility

Executive summary

Purpose of Intervention

This intervention, conducted at the Atomic Weapons Establishment (AWE) Aldermaston licensed site, was undertaken as part of the 2018/19 intervention plan and weapons sub-division strategy.

Interventions Carried Out by ONR

During the Office for Nuclear Regulation’s (ONR) January 2019 site inspection week, the ONR Site Inspector for UTC and PTC, and ONR specialist inspectors in radiological protection and mechanical engineering, conducted a planned System Based Inspection (SBI) of a process in the AWE Aldermaston Main Production Facility. Implementation of the licensee’s safety case for this process was sampled via compliance inspections against a number of Licence Conditions (LCs).

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

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A.

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

Conduct of the production process SBI was via examination of documentation and records, discussion with key plant personnel and inspection of the relevant plant areas. The key findings against each LC are recorded below:

LC 10 (Training) – Rating = Green

The training framework for the process inspected appeared to be comprehensive and diverse, with both in-house and external training to standards required by relevant external organisations and professional institutes. However, currently the training scheme is designed solely by the AWE specialism team leader, with no ownership from AWE’s Corporate Training Team. A new specialism strategy (which includes a focus on training) was presented during the inspection. Whilst ONR recognised that the new strategy is a work in progress, nonetheless it gave the ONR inspectors confidence that the licensee is working to address the issue with respect to ensuring that the training has scrutiny, ‘buy-in’ and ownership from the AWE Corporate Training Centre.

The operator of the process was very knowledgeable about the process and its safety provisions/safety case, but demonstrated poor safety case knowledge at the interface between this process and other operations (e.g. material moves) and exhibited a narrow outlook in this respect. Safety culture is recognised by the facility management as being an area requiring some attention and work is in-hand to improve safety culture in the facility which will help with problems such as this. Progress in this area is being monitored by both the ONR Site Inspector and by the licensee’s own Internal Regulator.

AWE was unable to demonstrate how they assure themselves that the maintainers of the process equipment (a long-term external contractor) continue to be Suitably Qualified Experienced Persons (SQEP) to carry out the maintenance activities. This topic is part of a wider AWE corporate issue but will be pursued during ONR’s February Site Inspection Week by the ONR Site Inspector as a part of his routine regulatory duties.

The training sampled was judged to be robust and comprehensive. Evidence was presented that the operator (who was knowledgeable in the process and its safety case) was fully trained and accredited. The licensee has work in-hand to address the shortfalls identified by our inspection. Therefore, given the above considerations, we were content that overall inspection against this LC merited a rating of ‘Green’.

LC 23 (Operating Rules) – Rating = N/A

The Operating Rules (ORs), specified in the Safety Case on a Page (SCoaP), for the process are generic (facility-wide) relating to material moves i.e. there were no ORs specific to the process. Material moves in the facility have already been sampled in a previous ONR SBI and hence we did not sample this area.

Although there are no ORs associated with the process itself, we advised that a thorough review of the SCoaP documents is required, as there were a number of inconsistencies observed. The licensee has already committed to such a review when its new safety case (resulting from its second periodic review of safety) is implemented.

Since there are no ORs relating to the process itself we did not rate this part of our inspection.

LC 24 (Operating Instructions) – Rating = Amber

The Maintenance Instructions (MIs) and Operating Instructions (OIs) sampled were found from an ease-of-use perspective to be of a good written standard, with clearly set-out instructions and effective use of photographs.

However, we observed that the facility is currently using a draft Manufacturing Process Specification (MPS) document at the point of work and was unable to adequately explain how the use of such a draft document is controlled. Additionally, the process operator currently has input to the writing of MPS documentation, and also reviews it; in our opinion this is a vulnerability in the independence of the authorship and peer review roles. It is also our opinion that the process team leader should be formally part of the review and approve process. The licensee accepted these findings and will address this as a part of implementation of its new process strategy.

A document containing information on contingency actions in the event of a failure of the Zone 1 vent has not been included in the process operating instructions. We provided advice that these contingency instructions should be incorporated into the overall OIs for the process. The licensee agreed to consider this advice.

Since we were concerned about the use of a draft MPS at the point of work and the identified vulnerability in the authorship/checking of MPS documents, we rated this part of our inspection as ‘Amber’ and an ONR Regulatory Issue will be recorded, to agree and track to closure a suitable course of remedial action with the licensee.

LC 27 (Safety Mechanisms, Devices and Circuits – SMDC) – Rating = Amber

We challenged AWE staff to show how they demonstrate that the process has been safely shut down. The licensee noted that a study to identify improvements in this area has been commissioned and a report of the findings will be issued shortly. We were content with this position but wish to see the report and obtain a commitment from the licensee to action the report’s recommendations.

It was noted on the plant walk-down that an e-stop on the process had been repurposed but was still coloured red. We provided advice that this is potentially misleading in an emergency situation and should be changed. The licensee accepted this advice.

Since we require action on the part of the licensee against our findings with respect to confirmation of process shut-down and the mislabelled e-stop, we recorded a rating of ‘Amber’ against this LC. A Regulatory Issue will be raised to agree and track to closure a course of action with the licensee.

LC 28 (Examination, Inspection, Maintenance and Testing – EIMT) – Rating = Green

The sampled documents were mostly found to be well written, in date and appropriately authorised. However, we noted the following observations that were raised with the licensee for action:

Two maintenance managers in the facility have the same role, and both have sign-off responsibilities for the same documents. We invited the licensee to consider whether this shared role presented any opportunities for important tasks to be missed. The licensee agreed to consider this advice.

We consider it positive that the licensee is currently updating its EIMT schedule to include an extra safety test.

Notwithstanding the above advice provided to the licensee, we were content that overall inspection against this LC merited a rating of ‘Green’.

LC 34 (Leakage and Escape of Radioactive Material and Radioactive Waste) – Rating = Green

Radiological protection surveys, including dose-rate and contamination monitoring, were shown to be in place and performed regularly. The surveys were shown to be recording very low levels of radiation and contamination.

The RPA was knowledgeable and engaged well to address our queries.

We were satisfied with the licensee’s arrangements for the control of material releases and hence gave this part of our inspection a rating of ‘Green’.

Conclusion of Intervention

LCs 10, 28 and 34 where rated as ‘Green’ (although noting that in the case of LCs 10 and 28 a number of pieces of advice were communicated to the licensee). In the case of LC 10 an ‘Amber’ rating was only avoided by the current quality of the training and the fact that the licensee already has actions in place to address our key concerns; ONR will track the LC10 actions as part of normal regulatory business.

In the case of LCs 24 and 27, it was our judgement that the inspection findings were significant enough to merit ONR oversight of actions designed to close these concerns. These LCs were hence rated Amber and ONR Issues will be raised, to agree and track to closure appropriate actions with the licensee.