Office for Nuclear Regulation

LC36 Central Support Function - Remote inspection

Executive summary

Purpose of Intervention

EDF Energy Nuclear Generation Limited (NGL) is entering a period of organisational change.  The Advanced Gas-cooled Reactors (AGR) are nearing end of generation and NGL is preparing for station closures, defuelling and decommissioning, which will impact on the Central Support Functions (CSF) located at Barnwood and East Kilbride. This was a planned Licence Condition 36 (LC36) compliance inspection of organisational capability within NGL’s CSF, completed in line with the inspection programme contained in ONR’s Operating Facilities Division Intervention Strategy for 2020-21. 

Interventions Carried Out by ONR

The inspection was undertaken by ONR’s EDF NGL Corporate Inspector and specialist inspectors from Leadership and Management for Safety and Nuclear Internal Hazards and Site Safety.  In addition, NGL’s Internal Nuclear Assurance (INA) supported the inspection.

The inspection focused on the implementation of the arrangements for the management of change (MoC) and the control of nuclear baselines. The inspection also supports the closure of ONR Regulatory Issue 6589, concerning adequacy of the CSF nuclear baseline and will inform on NGL’s wider preparations for change. The inspection was carried out remotely due to COVID-19 restrictions.

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

N/A.

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

Minor shortfalls were identified associated with the implementation of the MoC process and compliance with LC36 arrangements.  However, noting the scope of the MoC submissions and considering the associated risk, ONR is content that these shortfalls do not have a significant impact on safety and security at nuclear licensed sites.  However, NGL needs to make improvements to prepare for more complicated change programmes, where the aggregate of change and associated risk could have a significant impact on safety and security at nuclear licensed sites.  ONR is content that NGL is aware of these shortfalls and an improvement plan has been developed to address them.

ONR is content that adequate evidence has been provided to support closure of Regulatory Issue 6589 concerning the adequacy of the CSF nuclear baseline.  However, as NGL prepares to transform, ONR considers that the nuclear baseline needs to be defined using more robust methods and supporting evidence.  ONR is satisfied that NGL recognises that further changes are needed including better integration with business processes; identification of SQEP requirements and ownership within the functions.

Conclusion of Intervention

This inspection was rated Green (meets the minimum legal requirement).   One Regulatory Issue was raised regarding the implementation of the improvement plan associated with the MoC process and compliance with LC36 arrangements.  Progress will be tracked through Level 4 Meetings and Level 4 Regulatory Issue 8500.