This was a planned inspection of EDF Energy Nuclear Generation Ltd.’s (NGL’s) Hinkley Point B Power Station, undertaken as part of the planned intervention strategy for the Operating Facilities Division (OFD) of the Office for Nuclear Regulation (ONR).
The work was carried out in accord with the planned inspection programme contained in the Hinkley Point B (HPB) Integrated Intervention Strategy (IIS) for 2020/21 – conducted as a remote inspection to take account of the Government’s Covid-19 advice.
As part of this intervention one specialist Leadership and Management Safety inspector and ONR’s Nominated Site Inspector, carried out a remote LC36 organisational capability inspection, including preparations for end of generation and decommissioning. The inspection was supported by one nuclear security specialist inspector for meetings specific to the security organisation.
The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.
This is not applicable to this intervention as no system-based inspection was undertaken.
ONR considered that the station is using several processes to good effect (resource and succession planning; recruitment; leadership focus; employee engagement and communications; aspirational counselling). The station is also using NGL’s Management of Change (MoC) process, which sets out the resources needed to operate the station, as well as providing a structured process for managing organisational change.
ONR considered that station managers have a realistic appreciation of current organisational capability and recognition of where the vulnerabilities and gaps are. There is evidence that they are being managed appropriately. Organisational changes are mapped against NGL’s Reference Nuclear Baseline for Advanced Gas Cooled Reactors (AGR) and negative variances are justified. There is evidence that the threat of personnel leaving HPB to take up opportunities at Hinkley Point C (HPC) is being managed actively through the Generation to HPC People Pipeline.
We found that HPB’s current state of preparations for end of generation and defuelling is underpinned by a well-founded resource strategy and the Station is encouraged to maintain and update this as relevant information changes to reflect end of generation phases and proposals for organisational change in accordance with NGL’s arrangements. The Station needs to complete the development of strategic-level overarching MoC proposals up to the end of generation and to fuel free verification to provide frameworks for managing organisational change during these phases of the decommissioning programme.
Currently, the station’s strategy ends when all fuel has been removed from site and there is no discussion of ‘demand’ in terms of skills/ knowledge/capacity beyond this point. ONR understands that this work is being led by NGL’s Nuclear Decommissioning Business-Unit and is still subject to negotiations and agreement with Government. This remains a significant gap in the Station’s defuelling and decommissioning strategy.
Overall, based on our sample of interviews and document reviews, we judged that there are effective processes in place to manage and monitor human resources and organisational change. We identified a number of positive findings and we also identified some opportunities where the station can improve the effectiveness of its activities in this area and we have raised one Level 4 Regulatory Issue to ensure that the Station’s nuclear baseline organisation is justified fully where HPB’s organisation exceeds that specified in the AGR Reference Organisation.
From this inspection of LC 36, organisational capability, which examined the station preparations for end of generation at HPB, there were no findings that could significantly undermine nuclear safety. Therefore, a rating of Green, no formal action, was assigned to the inspection.