The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the AWE site licensee (AWE plc) against a strategy defined by the ONR Weapons sub-Division. In accordance with that strategy, a planned compliance inspection of Licence Condition (LC) 36 - Organisational Capability was carried out at a corporate level, and also on a selection of facilities and divisions, in January 2019.
Following the last planned inspection of this LC in 2017, ONR had issued a formal enforcement letter dated December 2017, identifying those areas of non-compliance that we expected to be addressed. The principal purpose of this inspection was to follow up on this formal enforcement, and to judge the extent to which the licensee had and was taking adequate steps to achieve compliance against Licence Condition 36.
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 the preparation for the delivery of this intervention, the following formal ONR guidance documentation was used:
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.
As part of the Inspection, ONR sampled a representative range of functional groups across the site to determine the adequate implementation of AWE's LC36 arrangements. It was observed that the governance of Organisational Capability including the Nuclear Baseline (NB) was inconsistent. Two out of the four functional groups sampled were unable to produce sufficient evidence to satisfy ONR that Organisational Capability was adequately managed and that they could identify and control all roles which could have an immediate or latent impact on nuclear safety.
To identify if the Nuclear Baseline was being maintained adequately, ONR sampled a number of organisational changes relating to the Baseline. ONR noted that, whilst the majority of the changes had some level of assessment, this oversight was reduced for lower level risks, and there was no evidence of adequate close-out of any of the changes. However overall, ONR was satisfied that the risks were being identified and managed proportionally.
The actions identified in the December 2017 enforcement letter were reviewed. AWE has completed a number of these actions. However the action requiring improvements to the adequacy of organisational change risk assessments was not completed and the extant arrangements are not consistent with ONR standards as defined in ONR Assessment guides.
AWE had made progress with enhancements to its Nuclear Baseline which had been completed and declared frozen prior to the Inspection. However, on review it was found to be incomplete and not adequately disseminated to the functions that were sampled during the Inspection. Therefore, it is judged that this aspect of the AWE LC36 arrangements has not been adequately implemented.
AWE has produced a resourced project plan for the implementation of LC36 arrangements. On review, a number of activities were declared to be 100% complete, but when sampled, in actuality were not. Also it was observed that activities that would be anticipated to have been included on the project plan are not. Therefore the project plan was found to be inadequate.
From the evidence sampled during the inspection, I (the ONR Lead Inspector) judge that there was sufficient evidence that the licensee’s formal arrangements for compliance with Licence Condition 36 are not being implemented adequately. Furthermore the extant arrangements do not meet the expectations of ONR in terms of the provision of adequate risk for organisational change; these expectations are summarised at our related assessment guides. I am therefore rating this inspection as Red, on the basis that extant formal enforcement expectations have not been addressed satisfactorily.
Additionally, in accordance with our documented processes, ONR will apply the Enforcement Management Model (EMM) to those shortfalls identified at this inspection, and will consider what further regulatory action is appropriate. As part of this process, ONR will also review the related ONR Regulatory Issues, specifically to determine if an elevated level of management oversight is required.