The purpose of the intervention was to assess the adequacy of NNB Generation Company (HPC) Limited’s (NNB GenCo) resource strategy and underpinning plans and their control of the Nuclear Baseline including change control.
Licence Condition 36 requires that NNB GenCo, as the Licensee, shall provide and maintain adequate human resources to ensure the safe operation of the licensed site. In addition, the Office for Nuclear Regulation’s (ONR) Safety Assessment Principles for Nuclear Facilities provides a framework for regulatory decision making, supported by Technical Assessment Guides (TAGs). TAG 65 refers to the ‘Function and Content of the Nuclear Baseline’ and sets out 9 principles, which ONR expects a licensee to use to underpin their Nuclear Baseline. This work is part of ONR’s on-going intervention plan that will inform the next major permission.
The intervention focused on gathering evidence as to whether the licensee, NNB GenCo, has adequate organisational capability including evaluation of the forward plans for addressing any shortfalls and providing assurance for the closure of Level 3 Regulatory Issue 6991. This includes the implementation of the resource strategy, the new nuclear baseline statement and nuclear baseline organisation charts.
ONR held Skype meetings on 26 May with relevant NNB GenCo personnel, and examined various documents.
The intervention was based on the key elements of the Level 3 Regulatory Issue 6991 which was raised on 5 February 2019 and gaining assurance that the shortfalls have, or are being adequately addressed.
NNB GenCo developed a resource strategy which was approved and issued. The newly formed Organisational Development Board is responsible for overseeing the delivery of the strategy. The Nuclear Resource Hub has been set up with a focus to deliver the strategy. The strategy outlines both internal and external resourcing factors using the support of the Nuclear Skills Alliance. It also sets out the 5 key phases of the project and the workforce roles by phase and the main activities and resourcing focus in each. ONR concluded that this was a significant improvement although it was recognised some further work needs to be done to further embed it across the business.
The approved resource plan is now a live document consolidating the approved medium term plans. It provides a single source of the headcount in each area and is shared on a monthly basis with the finance team and the Human Resources Business Partners. ONR considered this to be a positive advancement and noted future information technology improvements are planned.
The Nuclear Baseline Strategy 2020 has been approved in principle and the Nuclear Baseline Statement has been drafted. Once the Nuclear Baseline statement has been approved by the Organisational Development Board in June, it will be shared with ONR. This will enable ONR to assess it against ONR’s expectations.
The Nuclear Baseline statement contains a vulnerability analysis for the core capability with a narrative for each capability and mitigation measures. ONR concluded that considerable work has been done on improving and developing the vulnerability analysis.
The draft Nuclear Baseline statement sets out the current staffing levels against the new methodology defined in the Nuclear Baseline strategy. The new approach defines staffing against minima and optimum numbers. The draft Nuclear Baseline states where there are gaps in the current structure. ONR will seek to follow up this area post intervention to understand the basis in which NNB GenCo has justified the staffing levels.
‘Live’ Organisational Charts are now being produced on a monthly basis from the Nuclear Baseline database which contains all positions and roles. The charts have the oversight of the Management of Change (MoC) Committee and the Organisational Development Board for critical vacant roles; this provides additional rigour. ONR recognised that this is a valuable development and has now been in place for a number of months.
The effectiveness of the Organisational Development Board and MoC Committee and revisions to the MoC process will be covered through a targeted level 4 meeting and observations. ONR will observe the Organisational Development Board and how it operates, as well as the MoC process and its effectiveness.
ONR considered that overall an inspection rating of Green (no formal action) is appropriate for this intervention. This is because the intervention identified a number of key improvements that have been made by NNB GenCo and NNB GenCo was able to demonstrate that it is adequately managing its resources.
Post the intervention, ONR will follow up on elements of the Regulatory Issue that are yet to be fully implemented. This includes the new Organisational Development Board, which will provide the strategic oversight, and improvements to the MoC process.