Office for Nuclear Regulation

LC 36 inspection - Organisational Capability Preparations for end of generation and defuelling

Executive summary

Purpose of Intervention

This was a planned inspection of EDF Energy Nuclear Generation Ltd.’s (NGL’s) Hunterston 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 Hunterston B Integrated Intervention Strategy (IIS) for 2020/21 – conducted as a remote inspection to take account of the Government’s Covid-19 advice.

Interventions Carried Out by ONR

As part of this intervention two specialist Leadership and Management Safety inspectors and ONR’s Nominated Site Inspector, carried out a remote LC36 inspection organisational capability including preparations for end of generation and decommissioning.

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

ONR considered that the station is using a number of 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 covers both the station’s Nuclear Baseline, which sets out the resources needed to operate the station, as well as providing a structured process for managing organisational change. There is evidence of increased rigour behind its ‘people’ plan.

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. There is evidence of detailed succession planning.

We found that Hunterston’s current state of preparations for end of generation need to include a range of scenarios and noted that work is ongoing to address this. The station’s resource strategy then needs to be revised to reflect end of generation phases and proposals for organisational change in accordance with NGL’s arrangements. Station needs to develop an overarching management of change proposal up to the end of generation to provide a framework for managing organisational change during this period.

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 Waste and Decommissioning organisation 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 we believe the station can improve the effectiveness of its activities in this area.

Conclusion of Intervention

From this inspection of LC 36, organisational capability, which examined the station preparations for end of generation at Hunterston B, there were no findings that could significantly undermine nuclear safety.  Therefore a rating of Green, no formal action, was assigned to the inspection.