This intervention evaluated EDF Energy Nuclear Generation Limited (NGL) Investment Delivery organisation's governance arrangements and compliance with Nuclear Site Licence Conditions in the delivery of New Build projects. This intervention supports Office for Nuclear Regulation (ONR) Operating Reactors corporate strategic planning in evaluating NGL's project delivery capability and effectiveness in meeting requirements for reactor de-fuelling and decommissioning.
The intervention was performed in line with ONR’s guidance requirements (as described in our technical inspection guides) in the areas inspected.
The intervention was conducted through evaluating documentation and structured discussions with the following of NGL's project teams:
As this was not a Safety System Intervention, no judgement was given.
Based on evidence gathered during this intervention the following views were reached.
The Investment Delivery organisation demonstrated ability to manage project risk and mitigation through the stage gate process where projects are required to set out their justification to receive funding given their declared maturity and confidence in meeting declared commitments. The Project Review Committee (PRC) challenge assumptions based on its ability to act as a knowledgeable customer and to take on board the wider learning from previous projects.
Investment Delivery's involvement in project scope changes resulting from materialisation of risks is limited, with the Design Control Process used to manage these scope changes. However, Project Safety Review Group and Design Decision Panel which are aspects of the Investment Delivery process do influence outcomes of these scope change decisions.
Early visibility of commissioning requirements were identified by the investment delivery process including offsite requirements. However, a weakness was identified in NGL's corporate arrangements in that no single document exists to show the process that should be followed, these requirements being spread across a number of procedures. Investment Delivery has recognised this gap and is developing a document to show process which should be followed.
Based on evidence gathered from this high level review of NGL's Investment Delivery organisation and processes I concluded adequate governance arrangements exist for the delivery of new plant, these also taking into consideration compliance requirements of LC 19, 20 and 21.