This intervention was to inspect ICRC's compliance with Licence Conditions 35 (Decommissioning) and 36 (Organisational Capability), to understand its future plans and to have an open discussion on ONR’s regulatory expectations in both of these areas ahead of the implementation of ICRC’s organisational change and decommissioning programme. This was also an opportunity for ICRC to gain regulatory advice, and for ONR to gain confidence in and if necessary influence the direction of ICRC’s plans.
ICRC explained its plans for decommissioning and organisational change. I considered these against the requirements of the relevant licence conditions and regulatory guidance.
I was content that ICRC’s developing plans for decommissioning were broadly consistent with regulatory guidance, and that ICRC’s process for controlling organisational change met the spirit and broadly met the principles set out in regulatory guidance.
I considered that ICRC’s decommissioning and organisational capability arrangements were adequate for its current stage of activities ahead of decommissioning, and gave ratings of 3 for compliance against licence conditions 35 and 36.
I considered that ICRC’s contingency planning for the possibility of future recruitment and retention difficulties placed more emphasis on preventative steps rather than on mitigation or contingency measures, and that further departures of staff could result in temporary staffing difficulties. I explained that ONR would not allow any such difficulties, should they occur, to develop to affect safety, and emphasised that this needed to be considered by ICRC within its planning as a potential project delivery risk.
ICRC agreed to: