Office for Nuclear Regulation

Heysham 1 - LC36 Organisational Capability

Executive summary

Purpose of Intervention

The purpose of this intervention was to undertake compliance inspection activities at EDF Energy Nuclear Generation Limited’s (NGL’s) Heysham 1 power station in line with the ONR’s planned inspection programme contained in Heysham 1’s Integrated Intervention Strategy (IIS) for 2018/19.

The intervention was carried out by the ONR site inspector and an ONR leadership and management for safety (LMfS) specialist inspector who were joined by NGL’s independent nuclear assurance’s (INA) subject matter expert.

Interventions Carried Out by ONR

We undertook a themed inspection on the topic of Organisational Capability. This included a licence compliance inspection of NGL’s arrangements for Licence Condition (LC) 36 (Organisational Capability) which requires that ‘the licensee shall provide and maintain adequate financial and human resources to ensure the safe operation of the licensed site’.

The inspection is the first of three planned inspections across the fleet intended to evaluate the effectiveness of NGL’s arrangements for managing organisational capability both at stations and the corporate centre.

During this visit the Nominated Site Inspector also undertook meetings with the Licensee as part of routine information gathering and exchange.

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

No system based inspection was undertaken hence, this is not applicable for this intervention.

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

The station presented evidence to show how it was managing its human resources and managing organisational change.

We examined the station’s arrangements for managing its nuclear baseline (the means by which the licensee demonstrates that its organisational structure, staffing and competencies are suitable and sufficient to manage nuclear safety). We observed the station’s People Delivery Team (PDT) which was well run and reviewed the outputs of a number of sub-groups as well as reviewing the quarterly baseline statement of resources.

We reviewed the nuclear baseline with a range of Departmental Managers and we interviewed a range of staff about resourcing. We found they could clearly articulate their resource requirements and they all had a clear view on potential vulnerabilities in their Departments and could explain how they were managing these.

We reviewed capability requirements of the station’s Emergency Scheme and examined how resilience of roles within the scheme was managed. We judged the scheme to be well managed and there were clear succession and training plans in place.

We examined the arrangements in place for managing organisational changes and sampled a number of changes in order to judge whether they were appropriately categorised and whether risks were identified and managed.

Based on our sample of interviews, observations and document reviews we judged that there are effective processes in place to manage and monitor human resources and organisational change at Heysham 1.  We identified a number of positive findings and good practices. Some opportunities were identified for the station to further improve the effectiveness of its activities in this area. The Station is expected to address these improvements through their own internal management controls.

Our main finding related to the model baseline template contained within NGL’s corporate arrangements.  We considered this needed updating to help the sites identify the resources needed to maintain safety.  Since this is expected to be a corporate/ fleet wide finding we intend discuss this matter further with the NGL Corporate HR Fleet Manager to consider an appropriate way forward.

Overall, we judge the licensee was meeting relevant good practice when compared to ONR guidance and have therefore assigned a rating of Green (no formal action) for LC36 compliance.

Conclusion of Intervention

There are no findings from this inspection that could significantly undermine nuclear safety and no change is necessary to the planned interventions and inspections at Heysham 1 as a result.