ONR expects that the Licensee should have people in place who are competent to perform their roles, and that they actively manage their competence using adequate arrangements.
Phase 1 of the intervention focussed on gathering evidence on whether the Licensee, NNB Generation Company (HPC) Ltd (NNB), has adequate arrangements for defining, specifying and overseeing competency of NNB staff (including embedded contractors).
Phase 2 of the intervention focussed on gathering evidence on whether NNB has adequate competency management arrangements for the specific technical disciplines; Fault Studies, Mechanical and Electrical (M&E).
The purpose of the intervention was to gather evidence on:
ONR visited the offices of NNB, held discussions with relevant NNB personnel about the competence management arrangements, and examined various documents.
Competency Management System: NNB has a process for competency management which includes a signed Training Policy describing NNB’s vision of Training which is set out in 7 statements, entitled ‘policy standards’. There is a Training Strategy dated 2012 which focuses on operations and a suite of 6 core Training Procedures. ONR were informed that the Training Strategy is being revised and should be completed by the end of December 2019. ONR found that a competency management system was in place however the ‘training’ strategy should be reviewed and a strategy produced that covers the construction phase of the project (to complement the current strategy that concentrates on operations) and effectively cover the full lifecycle.
Competency assessment process: Competency assessments are carried out by NNB line managers, with the aid of SMEs (Subject Matter Experts), as required. The assessments are completed in an excel spread sheet and form the development/training plan. At annual performance reviews line managers are required to review the spread sheet for their staff and update it with the individuals’ progress. However, ONR judged that the completion of competency assessments is not consistent across all Directorates and compliance needs to improve.
In 2012 NNB recognised that a new online system for managing competency compliance was required. NNB are currently developing a cloud based system ‘HPC Track’, which is planned to be rolled out in 2020. ONR concluded that the move to the new IT system was positive however delays have impacted on NNB’s progress improving the competency management process.
Governance: There are governance arrangements in place however they are fragmented and no evidence was provided to show that NNB are driving adherence to the competency compliance process. ONR judged that there is a need for a review of the governance arrangements for competency management and this should include the roles, accountabilities and oversight arrangements.
ONR considered that overall an inspection rating of Amber (seek improvement) is appropriate for the organisational development work stream. This is because the intervention identified a number of improvements that are required, to ensure that NNB are able to demonstrate that they can effectively manage the competency of their staff.
ONR are proposing to raise a Regulatory Issue, to address the required improvements. These are relating to the competency management system and processes, governance arrangements and the need for a credible supporting system to manage and track competency assessments.