Office for Nuclear Regulation

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Compliance inspection of Licence Conditions 22 (modification on plant) and 28 (EIM&T)

Executive summary

Purpose of Intervention

The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Burghfield site licensee (AWE Limited) against a strategy defined by the ONR Weapons sub-Division. In accordance with that strategy, two Licence Condition (LC) compliance inspections were carried out on the Assembly Technology Centre (ATC), as planned, in March 2020. 

The purpose of these inspections was for the ONR to determine the adequacy of implementation of the licensee’s formal arrangements for compliance with LC 22 (modification or experiment on existing plant) and LC 28 (examination, inspection, maintenance and testing).

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.

As part of my preparation for the delivery of this intervention, the following formal ONR guidance documentation was used:

Explanation of Judgement if Safety System Not Judged to be Adequate

This was not a system based inspection, and therefore no judgement has been made of the adequacy of implementation of any part of the safety case.

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

During my inspection, I sampled evidence to determine the adequacy of compliance with the licensee’s formal arrangements for modification of plant systems and/or processes that affect safety.  Specifically, I concentrated on the categorisation of a sample of changes on plant, the performance of those facility staff assessing such changes, and the adequacy of implementation of a number of recent changes. 

On the basis of the sample that I reviewed, the related evidence was adequate and it has demonstrated that the licensee is implementing adequately their formal arrangements for compliance with Licence Condition 22.  I noted that the licensee had already identified a shortfall associated with periodic assurance of the modification process; I have raised an ONR Regulatory Issue at Level 4 to monitor progress against this shortfall. 

Additionally, I sampled evidence associated with the licensee’s compliance with its formal arrangements for examination, inspection, maintenance and testing for areas of plant that may affect safety within the Assembly Technology Centre. Specifically, I examined the status of maintenance delivery on plant, and sampled records of maintenance completed. 

On the basis of the sample that I reviewed, the related evidence was adequate and it has demonstrated that the licensee is implementing adequately their formal arrangements for compliance with Licence Condition 28.

I consider that, for both licence conditions, the licensee has broadly complied with all legal duties, and that there are only limited opportunities for further ALARP improvements.  Therefore, it is my opinion that, against compliance with Licence Conditions 22 and 28, an inspection rating of Green (No Formal Action) is merited

Conclusion of Intervention

Based on the evidence sampled during these compliance inspections, I judge that there was sufficient evidence that the licensee’s formal arrangements for compliance with Licence Conditions 22 and 28 are being implemented adequately.

Noting that the safety significance was minor, I have raised an ONR Regulatory Issue at Level 4, to seek sustained compliance with the element of LC22 corporate arrangements relating to periodic review.