Office for Nuclear Regulation

LC 36 Inspection – Parent Body Organisation transition

Executive summary

Purpose of intervention

The purpose of my intervention was to assess the adequacy of Research Sites Restoration Limited (RSRL’s) arrangements for compliance with Licence Condition (LC) 36 (Organisational Capability) and their implementation.  I did this with reference to the RSRL’s management of the transition to a new parent body organisation (PBO).  Share transfer to the new PBO (Cavendish Fluor Partnership) was completed on 1 September 2014 and RSRL is currently in the consolidation phase in which proposals captured in the parent body agreement are reviewed and incorporated into RSRL’s plans, following any necessary change processes.  Part of these consolidation activities is an application by RSRL / Magnox Limited (submitted to ONR on 28 November 2014) for relicensing of the Harwell and Winfrith sites.

Interventions Carried Out by ONR

The scope of my intervention comprised:

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

In November 2014 RSRL completed a post implementation review of the PBO transition, as per the commitment given in its management of change documentation (submitted to ONR in September 2013).  This was led by RSRL’s Internal Regulation Manager and included a review of transition close-out as well as planning, communications and monitoring in the consolidation phase.  The review concluded that the transition was well managed but identified opportunities for improvement in the consolidation phase, including better management of consolidation activities and finalisation / implementation of the communications strategy.  The review made a number of recommendations which have been forwarded to the individuals concerned (mainly RSRL’s directors) for action.  Overall I considered the review to have been well executed, in accordance with industry good practice.  However, I took the opportunity of my LC36 inspection to follow up on some of the issues the review identified (see paragraph 5 below).

I found RSRLs LC36 compliance arrangements to be broadly in line with ONR’s expectations, as per NS-TAST-GD-065, and the nuclear industry’s code of practice.  I also found, overall, satisfactory implementation of the arrangements at Winfrith, although with the opportunity for more consistent representation of intelligent customer capability, identification of a wider range of resource vulnerabilities and greater engagement of the Dragon project in the work to enhance RSRL’s engineering capability.  RSRL is taking action to address each of these improvement opportunities.  RSRL is also continuing its nuclear baseline awareness / training programme and improving the reporting of organisational capability issues to the Executive.  RSRL has recognised the need to take a more holistic approach to changes affecting its management system, lifetime plans and organisation (knock-on effect of one to another). 

I found scope for improvement in RSRL’s management of the demand on its resources (particularly the support functions) arising from PBO consolidation phase activities, eg the planning of organisational changes post Harwell / Winfrith re-licensing and the rationalisation of elements of RSRL / Magnox Limited’s management systems.  In my judgement this represents significant ongoing work, with potentially challenging timescales, the full scope of which does not appear to have visibility at senior level within RSRL.  Also there does not appear to be a formal process by which resources for such work are managed so as not to impact RSRL’s day-to-day licensed undertakings.  This issue is recognised by RSRL and echoes the findings of the internal regulation team’s transition review.

Conclusion of Intervention

Overall I found RSRL’s arrangements for compliance with LC36 and their implementation, to be adequate (Integrated Intervention Strategy rating of 3).  However I identified one issue for follow-up, namely for RSRL to demonstrate to ONR that it understands and is managing the resource demand arising from PBO consolidation phase activities (particularly on support functions) so as not to be detrimental to its day-to-day licensed undertakings.  I will follow-up on this issue as part of planned interventions associated with the Harwell / Winfrith relicensing application.