ONR review of the development of the AWE Structured Improvement Programme
This report reperesents our position with regard to the development of the AWE Structured Improvement Programme (SIP) as of August 2018.
AWE Aldermaston and AWE Burghfield licensed sites operated by AWE plc (referred to as AWE), are both subject to ONR enhanced regulatory attention. AWE has developed a significant programme of corporate level improvements that are designed to address identified shortfalls in safe operations, process, change, and stakeholder interactions. These improvements form the SIP.
On the basis of our engagement to date, ONR considers that the SIP is adequately developed, is now in the implementation stage and that the risks associated with non-delivery are being managed appropriately by AWE.
However, ONR recognises that successful forward delivery of the SIP is predicated on a sustainment of the level of commitment and proactive governance that is currently being demonstrated by the AWE leadership.
ONR view on the development of the AWE SIP
- The two licensed sites controlled by AWE (AWE Aldermaston and AWE Burghfield) have been in enhanced regulatory attention for circa 5 years. Following a number of regulatory interventions that identified shortfalls in safety performance, nuclear site licence compliance and delays in the delivery of key nuclear projects, ONR and AWE agreed in early 2017 that there was benefit in performing a structured analysis to identify root causes of shortfalls in safety and compliance performance, and to develop a programme of improvement actions. This was prompted, in part, by AWE’s declared commitment to drive a change in its own performance.
- An initial stakeholder workshop, including ONR inspectors (‘Workshop 0’) in April 2017 identified a number of ‘themes’ which were used to structure a series of further workshops. These workshops were attended by representatives from AWE management and its stakeholders, including ONR inspectors, and identified a range of root causes for each of the defined themes.
- During 2017 and into early 2018, AWE developed a programme of work, referred to as the AWE SIP, which along with other AWE change programmes would address these root causes through the delivery of a large range of improvement initiatives, including aspects of organisational culture, practice, and capability. This work was divided into a number of work streams, with specific projects under each work stream devised to address a number of related root causes.
- The development of the content and focus of the SIP has been led by AWE. During the process, ONR has provided regulatory advice and guidance in respect of its wider aims.
- From the start of the development of the SIP, the AWE Executive has taken ownership of the content and delivery, and has focused on developing it as a fully integrated business change programme. Additionally, the language used by AWE to describe the SIP, and to define its scope and purposes, indicates that the organisation views the SIP as part of their overall business transformation as it incorporates both potential benefits for the business, and improvement in its operational performance (including safety and compliance).
- AWE has now divided the SIP improvement activities into four work streams: Safe Operations, Process, Change, and Interactions. The AWE Executive has apportioned lead responsibility between a number of its directors for each of the four work streams, and has also identified an AWE delivery lead for each work stream who will oversee the performance and management of all individual projects under that work stream. Governance of the SIP is enabled through AWE’s formal project management process. All four work streams have passed internal AWE project review gates up to Stage Gate 3, which is the point at which every part of those work streams should be: fully resourced, have a suite of fully scoped project definitions, have all interfacing relationships defined, and be integrated into the management of the business.
- As well as producing outcomes that are identifiable as operational improvements, a significant proportion of the SIP is aimed at delivering long term cultural change within the organisation. Improvements in the licensee’s safety and compliance culture, including taking account of safety in all aspects of their decision making, will ensure that the value of such an approach is understood across all levels of the organisation. ONR supports this approach.
- As part of its regulatory interventions, ONR has started to review the content and scope of the projects that sit under each of the four work streams, with an individual inspector from the ONR Weapons Sub-Division responsible for engagement with the related AWE delivery lead for each work stream. ONR engagement through to August 2018 has not identified any major issues with the scope/content of the SIP.
- As a result of regular interactions, and based on sampling evidence available to date, ONR is currently of the opinion that the scope of the SIP has the potential to promote and sustain a range of safety and compliance related improvements that will be of benefit to AWE as a nuclear licensee.
- ONR recognises that AWE has developed the SIP alongside an effective governance framework with Executive level oversight. This should reduce the risk that any changes in personnel have an adverse impact on the pace and performance of SIP delivery. However, ONR notes that, as the SIP includes elements of cultural change (which is sometimes hard to achieve), it is vital that AWE maintains the quality of that oversight in order to maintain momentum through the delivery stage and into benefits realisation.
- ONR will continue to engage regularly with AWE during the delivery phase of the SIP, providing advice and guidance via planned monthly SIP stakeholder interactions, and seeking evidence of outcomes and benefits through wider strategic interactions as the delivery phase progresses.
- As part of those interactions, ONR Weapons Sub-Division inspectors will undertake periodic review of the conduct of the licensee, with specific focus on their performance against a number of criteria, which form part of an established process already in use by ONR to determine the level of regulatory attention merited going forward by each licensed site in the UK.