Executive summary
Date(s) of inspection:
September 2023
Aim of inspection
To assess the effectiveness of AWE’s strategy for the management of maintenance of safety significant Structures, Systems and Components (SSCs) in response to the reduced capacity and capability of SQEP maintenance resource, and the implementation of that strategy across the key operational areas across both sites to demonstrate compliance against the requirements of LC28 and the regulatory expectations defined within ONR’s NS-INSP-GD-028 (Version 8.1).
This inspection will be within UTC (to reconcile with IR-52610 (that scope copied below))
Subject(s) of inspection
- LC28 - Examination, inspection, maintenance and testing - Rating: GREEN
Key findings, inspector's opinions and reasons for judgement made
This inspection at UTC on the AWE Nuclear Licensed Site was undertaken as part of a programme of planned inspections across a number of AWE facilities for 2023/24. The scope of the intervention was aligned to the ONR/ AWE Strategy and was to judge the adequacy of AWE’s implementation of its arrangements made under LC 28 with a focus on the management of maintenance backlogs.
I, a Mechanical Engineering Specialist Inspector for the ONR Weapon's programme, undertook a Licence Condition 28 (Examination, Inspection, Maintenance and Testing (EIMT)) inspection at the UTC former enriched uranium (EU) production Facility on the AWE Aldermaston site i.e. A**, I was supported by the ONR UTC Site Inspector; an ONR Leadership and Management for Safety (LMfS) Specialist Inspector; and an Inspector from the Environment Agency. Details of the Environment Agency focus for the inspection can be found in their RASCAR (RadioActive Substances Compliance Assurance Report) and are not repeated here. The inspection focussed on seeking assurance that AWE/UTC is:
- managing any maintenance backlog;
- assigning adequate SQEP resource to EIMT activities;
- able to justify the deferral of any maintenance;
- managing stores effectively and ensuring that SSC labelling is fit for purpose;
- managing Regulatory Issues associated with LC28 activities; and
- planning daily and weekly EIMT activities appropriately.
I carried out an LC28 compliance inspection at the AWE Nuclear Licensed Site, UTC former EU production facility A**. I reviewed the management arrangements for LC28 and was able to establish the “golden thread” in the management system for this LC.
I sampled the evidence for maintenance backlogs; staff capability for undertaking EIMT; the deferral process for not undertaking maintenance; SSC labelling; extant LC28 Regulatory Issues (managed via WIReD); and daily/weekly EIMT planning and from these interventions, it is my opinion that the procedures and controls evidenced by AWE demonstrated that Relevant Good Practice had been observed and AWE was following its own procedures and that the requirements of LC28 had been satisfied. AWE presented a clear auditable trail for all of the areas sampled and demonstrated good control of documents, records and certifications.
Conclusion
Agenda items that were solely owned by the EA are not included in this judgement.
The intervention sought to sample certain areas associated with LC28. These were: EIMT backlogs; staff capability; the process of deferring EIMT; storage facilities and SSC labelling; managing extant Regulatory Issues; and EIMT work planning. These will be considered individually based on the evidence presented:
EIMT backlogs - Evidence was presented that showed up-to-date backlog information. Whilst there was a backlog, which comprised mostly of breakdowns, it was not significant percentage of the total AWE backlog.
Neither was it a significant percentage of the assets requiring EIMT within the facility. AWE was able to show that the backlog was well understood and being managed appropriately. On balance I was satisfied that the EIMT backlog in UTC was not a concern.
Staff capability - I noted that potential improvements in EIMT capability (as a result of 'Project Glasgow'), specifically, the introduction of a Principal Maintenance & Reliability Engineer had not yet been fully realised - the PM&RE had only recently been deployed. In addition, the cadre of existing maintenance engineers was lower than planned. IR-52730 had identified that EIMT capacity was a known corporate issue that was being addressed. Whilst UTC had some work to do to embed the M&RE and recruit standard maintenance engineers, on balance I was satisfied that UTC was managing EIMT capability/capacity appropriately.
EIMT deferral - UTC followed corporate arrangements to defer maintenance by use of the ACR process. The process was sampled for 3 items with one issue being found. This issue was quickly dealt with to my satisfaction. I also sampled the management loading of ACRs and was content that managers were not over-loaded. I was therefore satisfied that the EIMT deferral process was adequate within UTC.
Storage facilities - UTC did not have any local storage facility.
SSC labelling - Labelling was recorded for several SSCs during the walkdown and then checked back in the office. The details of one label appeared to be missing. In addition advice was given regarding the quality of some of the label fixings. Despite these shortfalls, most labelling was in good order and I was therefore satisfied with SSC labelling within UTC.
Regulatory Issues - UTC had made slow progress in producing validated Maintenance Instructions where these had been required by RIs 10478 and 10481. This situation was deemed acceptable as existing MIs could still be used for EIMT tasks. A sample of un-validated MIs was taken for later review. This item will not be rated here as it is being managed via WIReD.
EIMT work planning - I observed and discussed PLOD and PLOW arrangements and was satisfied that EIMT work was being adequately planned.
I judge that overall there were no significant concerns with EIMT backlog; EIMT capability/capacity; the use of the EIMT deferral process; the labelling of SSCs; and EIMT planning. I therefore rate this inspection as Green.