Office for Nuclear Regulation

Corporate - LC36 Intervention

Executive summary

Purpose of Intervention

The purpose of this intervention was to undertake compliance inspection activities at EDF Energy Nuclear Generation Limited’s (NGL) headquarters at Barnwood, Gloucester in line with the ONR’s planned inspection programme contained in the Corporate Integrated Intervention Strategy (IIS) for 2018/19.

Interventions Carried Out by ONR

We performed a routine compliance inspection to evaluate NGL’s resource management processes in accordance with LC36 (Organisational Capability). We focused on NGL’s Corporate Support Functions (CSF).

The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.

Explanation of Judgement if Safety System Not Judged to be Adequate


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

We undertook an inspection against LC36 which examined NGL’s arrangements to maintain adequate human and financial resources. Based on a sample of Nuclear Baselines (for the Health, Safety and Environment; Supply Chain and Independent Nuclear Assurance functions) and discussions concerning management of human resources including resource management; succession planning and management of change, we were satisfied that NGL has effective processes to manage and monitor human resources necessary to support safe operation of NGL’s operational sites.

Managers from NGL’s CSF presented evidence to show how posts and roles significant to nuclear safety are identified in nuclear baseline statements and how resources are monitored and managed. We found some apparent inconsistencies in how nuclear baseline resources were identified within nuclear baseline statements and there was limited information justifying resource levels. A nuclear baseline statement for the whole organisation is under development.

We noted that a CSF People Delivery Team has been established to enhance cross functional resource planning and to provide oversight across all of NGL’s corporate support functions. A management of change sub-group is being formed to enable organisational changes to be considered more strategically and for the impact of aggregate changes to be more clearly visible.

We sampled examples of organisational changes made or in the process of implementation and noted good process adherence to the Licensee’s Management of change Process. We noted appropriate governance arrangements were being implemented with respect to the provision of services by NGL.

Conclusion of Intervention

Whilst we noted some inconsistencies in the derivation and justification of Nuclear Baseline statements, we did not identify matters that have potential to impact significantly on nuclear safety.

At present, no additional regulatory action is needed over and above the planned interventions at Barnwood as set out in ONR’s Corporate IIS plan which will continue as planned. We judged the standard of compliance to be in accordance with relevant good practice and assign the following inspection rating against LC36: Green.