Executive summary
Date(s) of inspection:
- January 2024
Aim of inspection
In accordance with the Office for Nuclear Regulation’s (ONR’s) Operating Reactors Strategy, each year ONR performs a series of planned inspections to seek assurance regarding the adequacy of arrangements made to comply with Licence Conditions (LC) and the effectiveness of their implementation. This inspection was a Licence Condition 13 – Nuclear safety committee inspection.
Subject(s) of inspection
- LC13 – Nuclear safety committee – Rating: Green
Key findings, inspector’s opinions and reasons for judgement made
I saw evidence that, in keeping with the NSC terms of reference, NGL is holding quorate NSC meetings at which there is meaningful consideration of matters referred to it for consideration and advice. I found that, where appropriate, challenges were being made in an open, constructive and robust manner. I saw evidence that NGL routinely provide ONR with a signed copy of the record of the NSC within the 14 days required by LC13(8). NGL demonstrated that when ‘Formal Advice’ is raised by the NSC this is effectively recorded and tracked and progress reported on at the NSC and to the Board.
I found that NGL do provide ONR with the appropriate information when a person is appointed to the NSC. I saw evidence that the NSC membership is appropriate for the lifecycle phase of the installations. As recognised by the NSC Chair, given the changing role of NGL there is a need for the Chair to remain vigilant regarding the composition of the NSC. I found that NGL adopt an open-minded approach when undertaking a periodical review of the effectiveness of the NSC.
Whilst I saw evidence that NGL were compliant with the requirements of LC13, I found that NSC Minutes could be clearer on when matters are referred to it for consideration and advice rather than for information. Also, I found that the Minutes could be clearer with regard to the outcome of discussions. This was in particular with regard to the status of papers, advice given, and actions placed.
I found that NGL’s approach was generally consistent with the seven principles, and associated guidance contained in ONR’s LC13 Technical Inspection Guidance. In several instances I found minor shortfalls and provided NGL with advice to consider on how to address these aspects.
Conclusion
I judge that NGL’s LC13 compliance arrangements and their implementation have meet the specific legal requirements of LC13, and that the NSC is effective. However, I consider that NGL could improve the clarity of the NSC Meeting records by always clearly identifying when individual matters are referred for consideration and advice, and recording the Chair’s summary of the outcomes of the discussions of such matters. Noting the ONR guidance on inspection ratings, it is my opinion that an inspection rating of Green is merited.
I have raised a Level 4 Regulatory Issue to have oversight of NGL’s plans to improve the clarity of the Minutes. I have also provided advice relating to minor shortfalls identified against the ONR expectations in TIG-13. The NSC chair has confirmed that NGL will carefully consider the advice provided.