- Site: N/A
- IR number: 22-011
- Date: May 2022
- LC numbers: 36
This was a planned inspection of organisational capability in EDF Energy Nuclear Generation Ltd (NGL’s) Central Support Functions (CSFs). The inspection was undertaken in accordance with the ONR’s Operating Facilities Division Integrated Intervention Strategy for 2022-23. The CSFs provide a range of capabilities to support NGL’s fleet of nuclear power stations. NGL is embarking on a period of wide-ranging business change, driven primarily by end of generation of the Advanced Gas-cooled Reactor fleet. This transformation programme includes reshaping and rightsizing the CSFs. The purpose of the inspection was to seek confidence that NGL is maintaining adequate organisational capability in the CSFs to support its fleet of power stations from a safety and safeguards perspective.
Interventions Carried Out by ONR
The inspection was carried out at NGL’s Barnwood offices on 3-5 May 2022. It covered compliance with the requirements of Licence Condition (LC) 36 (Organisational Capability) and the Nuclear Safeguards (EU Exit) Regulations, 2019. The scope of the inspection was as follows:
- Implementation and effectiveness of the controls by which NGL is managing its transformation;
- Adequacy of the CSFs nuclear ‘baseline’ (the means by which NGL demonstrates the adequacy of its organisational capability);
- Implementation and effectiveness of recent organisational changes; and
- Adequacy of NGL’s progress in developing its safeguards capability.
Key Findings, Inspector’s Opinions and Reasons for Judgements Made
Control of transformational change In its transformation documentation, NGL has set out enhanced arrangements for management of the organisational change in the CSFs. However we found that not all of these arrangements are in place or mature, e.g. the Organisation Capability Committee has been established as the “controlling mind” on organisational capability but is not yet exercising the full range of its terms of reference, and the Fleet Management of Change Oversight Group is not yet in place. Furthermore, there are eight open ‘Amber’ comments from a review NGL’s Independent Nuclear Assurance team undertook in February 2022 of the Phase 1 changes to the CSFs. NGL has recognised that it needs to improve the maturity of its arrangements for managing organisational capability and is currently proceeding with changes to the CSFs in a cautious manner. However we found that NGL did not have a clear plan for ensuring that the necessary pre-cursors are in place before further significant change occurs.
CSF nuclear baseline In considering NGL’s most recent review of the nuclear baseline for the CSFs, we found similar shortfalls to the equivalent reviews undertaken at stations (subject to an existing regulatory issue). While the review summarises the vulnerabilities in the CSFs and mitigating action, it is undertaken on an annual basis only and therefore doesn’t provide a clear view of current (and potential future) capability risks and the adequacy of mitigating action. NGL is addressing this shortfall through its organisational capability improvement plan. In the meantime, NGL showed us enhanced processes which the Engineering and Design Authority teams have put in place for more regular review of the baseline, and that Supply Chain is developing for competence management, which are a useful step forward. We considered it important that NGL has a clear view of its organisational capability risks to ensure that planned changes are built on solid foundations.
Recent organisational changes We examined recent organisational changes made in the CSF . These showed a largely positive picture of how NGL is managing change at a functional or team level, while addressing the recognised shortfalls in its LC36 arrangements. Key factors were the interim support and oversight being provided by the Nuclear Skills Alliance, the role of the functional change leads and the clear expectations set by directors on management of organisational capability.
Safeguards capability We inspected the Safeguards function against our expectations as set out in the ONR Nuclear Material Accountancy Control and Safeguards guidance. We found that NGL’s current structure, governance, and oversight arrangements are adequate. We also found that the Safeguards function is moving towards adequate competence management arrangements and personnel resilience.
Conclusion of Intervention
We conclude that there are shortfalls in NGL’s arrangements for managing the organisational changes associated with its transformation programme. We judge these to be significant because they risk ONR being unable to make a positive permissioning decision on the more significant changes to come. We have therefore rated this aspect of the inspection ‘Amber’ (seek improvement). We have raised a regulatory issue for NGL to establish the relevant controls prior to further significant change taking place.
As regards NGL’s Safeguards capability, we conclude that NGL is making suitable and sufficient progress in developing its capability and have therefore rated this aspect of the inspection ‘Green’ (no formal action).