Office for Nuclear Regulation

DRDL management of the organisational change proposal against LC36 compliance arrangements

Executive summary

Purpose of Intervention

The purpose of this ONR intervention was to undertake a planned inspection at DRDL, Plymouth, in accordance with ONR’s Intervention Plan for the regulation of DRDL 2018/19.

Interventions Carried Out by ONR

ONR undertook an intervention to examine DRDL’s application of the Management of Change (MOC) process to the Headcount Reduction organisational change proposal, 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, ONR Nuclear Safety Technical Assessment Guide (TAG) 080, NS-TAST-GD-080 Rev. 3, Challenge Culture, Independent Challenge Capability (including an Internal Regulation function) and the provision of Nuclear Safety Advice, 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

On the basis of the areas sampled during the intervention, I judged that DRDL had adequately applied their LC36 arrangements in the production and governance of the MoC proposals and that Relevant Good Practice (RGP) had been applied by the licensee in many areas, with no major shortfalls identified.  The licensee’s categorisation of the overall MoC and supporting business unit annexes, harmonised with the criteria within their arrangements and were judged reasonable with respect to assessed nuclear safety impact.

DRDL’s LC36 compliance arrangements are relatively new, with significant improvements introduced by the licensee during 2017 and 2018, and the Headcount Reduction MoC proposal is the first organisational change to be managed within the framework of these arrangements.  While evidence of improvements was observed in the planning and production of the organisational change proposals, it was not therefore possible to assess the effectiveness of the licensee’s implementation of the organisational change. 

With respect to permissioning strategy, I recommend that ONR should consider taking the DRDL Headcount Reduction MoC proposal for information only and that Enhanced Implementation Monitoring and Control (EIM&C) of the organisational change by ONR will be required, with particular attention in the areas of governance of implementation and hold-point management and control.

Conclusion of Intervention

Based on the evidence sampled during this inspection I judged that measured against ONR’s expectations for LC36 (Organisational Capability), for the management of 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, four regulatory observations (areas for improvement) and no regulatory issues.