Executive summary
Date(s) of inspection
November 2023
Aim of inspection
The aim of the inspection was to:
- assess the implementation of interface arrangements by the nuclear site licence companies (NNB Generation Company (HPC) Ltd (NNB GenCo), Nuclear Generation Limited (NGL) (Nuclear Operations) and Sizewell C Ltd (SZC Ltd) (as a prospective licensee)), covering interface, oversight and control of work conducted by EDF Nuclear Service (NS), formerly Technical Client Organisation/Technical Services Organisation (TCO/TSO); and
- gain confidence in the robustness of the arrangements and to understand forward plans for implementation of the next phase of NS as it becomes a standalone organisation, jointly owned by the licensees it supports. This inspection was conducted ahead of enacting the change.
This inspection was conducted jointly between EPR, NGL and security regulation, enabling efficient and effective engagement, incorporating a cross purpose assessment. The objective was to assess the licensees' and prospective licensee’s ability to maintain control (e.g. of the nuclear baseline, intelligent customer arrangements and delivery of work activities) through the NS arrangements, as we regulate the licensees.
Subject(s) of inspection
- LC 17 - Management systems - Rating: Not rated
- LC 36 - Organisational capability - Rating: Not rated
Key findings, inspector's opinions and reasons for judgement made
The inspection found that:
- there are no significant shortfalls in current arrangements for oversight and control of work conducted by EDF Nuclear Services (NS) on behalf of the licensee; and
- the arrangements for control and oversight of NS are not yet sufficiently robust for implementation of the next phase of development of NS.
ONR has provided written advice on its expectations for the arrangements that should be in place for the next phase of development of NS. This covers aspects such as the need for a clear strategy and plan, clear governance and oversight arrangements and more robust management arrangements within NS.
Conclusion
Following the inspection we have encouraged NNB GenCo, SZC Ltd, NGL and NS to use 2024 as a period of ‘shadow working’ to stress test the arrangements and incorporate learning, prior to implementing Phase 2. We will seek periodic updates with licensee / NS representatives.
ONR has set out areas of focus in a letter to all licensees, that should be addressed prior to implementation of Phase 2 and will be considered as part of a readiness inspection ahead of Phase 2 implementation.
ONR has chosen not to rate this inspection due to the wide-ranging scope and the number of licensees involved. We consider that a single RAG rating would not be of benefit at this stage given the evolving nature of the Phase 2 proposals and that implementation is now not likely until quarter 2 or quarter 3 2024.