Office for Nuclear Regulation

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Hinkley Point C - LC36 compliance arrangements

Executive summary

Purpose of Intervention

The purpose of this ONR intervention was to undertake a planned inspection at NNB GenCo (HPC) [NNB], Bridgewater House Office, Bristol, in accordance with ONR’s Intervention Plan for the regulation of HPC 2018/19.

Interventions Carried Out by ONR

ONR undertook an intervention to examine NNB’s application of the Management of Change (MOC) process to organisational change, including a LC36 (Organisational Capability) compliance rating.

ONR utilised the following guidance during this intervention: ONR Nuclear Safety Technical Assessment Guide (TAG) 048, NS-TAST-GD-048 Rev. 4, Organisational Capability, and the Nuclear Baseline and the Management of Organisational Change, A Nuclear Industry Good Practice Guide, Safety Directors Forum, Issue 3, March 2017.

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A – this was not a Safety System inspection.

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

Based on the evidence sampled during this inspection ONR judged that measured against ONR’s expectations for LC36 (Organisational Capability), for the management of the organisational change with respect to LC36 (2) and LC36 (5), the intervention rating is GREEN (no formal action), with identification of three areas of good practice and one regulatory issue (Level 4).

The areas of good practice related to the production of a plan for organisational capability improvement and development, carrying out learning activities with other licensees for organisational change management, and delivering improved guidance and training for change proposal authors.

The Level 4 regulatory issue related to improvements and further strengthening of the Management of Change Committee (MOCC) in the areas of sampling of lower category changes (insignificant and below scale), examining the cumulative effect of changes and scrutinising the implementation of change proposals.

Conclusion of Intervention

In the opinion of the ONR inspectors, the LC36 arrangements were judged as adequate and further examination will take place as the identified improvements are implemented and reviewed.