Date(s) of inspection
- June 2023
Aim of inspection
Licence condition compliance inspections are an essential element of ONR’s overall intervention strategy on any nuclear site.
This was a planned LC36 inspection of HYB’s organisational capability to maintain nuclear safety that focused on the station’s:
- Governance, oversight and management of resources to maintain nuclear safety and the strategy for ensuring the maintenance of adequate SQEP;
- Governance, oversight and management of organisational change.
Subject(s) of inspection
- LC36 – Organisational capability – Rating: Green
Key findings, inspector’s opinions and reasons for judgement made
This planned inspection assessed Heysham 2’s (HYB) organisational capability to maintain nuclear safety and management of organisational change against NGL’s extant arrangements. It was, however, conducted in the context of a series of systemic organisational issues which are subject to existing Level 3 regulatory issues and are being addressed through a corporate LC36 improvement plan.
I reviewed HYB’s annual baseline statement and people plan and sampled records of the People Meetings, Organisational Capability Reviews and Resourcing Special meetings. From this, I held focused discussions on the capability of the organisation and implementation of arrangements at all levels in the organisation from Station Director to Team Leader plus discussions with Site INA and Safety Representatives and members of the Local Joint Committee.
I found that:
- HYB’s nuclear baseline management is conducted fully in accordance with NGL’s arrangements;
- During the recent statutory outage however, station leadership had identified shortfalls in the resourcing and capability of high-significance, infrequently used, formal Authorisation roles.
I judge that the gaps in the capability of role holders arose from a known shortfall in NGL’s organisational capability arrangements regarding the identification of nuclear baseline roles.
This is identified within RI 10695 (Justifying the Adequacy of the Nuclear Baseline) and is being addressed through the corporate LC36 improvement plan. I advised station leadership to discuss the lessons identified with the owner of the LC36 Improvement Plan and I have briefed the Nuclear Skills Alliance during an ONR-NGL Organisational Capability Level 4 meeting.
In preparation for the inspection, I sampled a selection of approved MoC proposals and records of the oversight provided by the MoC Steering Group before conducting targeted discussions with the MoC authors, members of the MoC Steering Group and personnel impacted by the implementation of the changes.
I found that:
- All personnel involved in the implementation, management and oversight of NGL’s MoC arrangements had an adequate understanding of those arrangements and that changes had been communicated effectively to those impacted;
- The station had approached the changes associated with the implementation of off-load, depressurised refuelling (ODR) as a series of discrete, independent changes. This constitutes ‘salami slicing’ in accordance with ONR’s guidance (NS-INSP-GD-036), with the risk that the interfaces between related enacting MoCs and the aggregated risk of the changes may not be considered adequately. Following ONR advice, the station had conducted a retrospective ‘Quick Hit Self-Assessment’ of the risks associated with the approach to the ODR-related MoCs. By sampling the quick hit self-assessment and the relevant MoCs, I found that the station had demonstrated adequate management of safety through the changes.
I judge that the shortfalls in the management of large-scale, complex change arose from:
- A known issue in NGL’s management of change arrangements that is identified as a specific shortfall in RI 10696 (Implementing Adequate Organisational Capability Arrangements) and is being addressed through the corporate LC36 improvement plan;
- The station being unaware of ONR’s guidance and relevant good practice, which I shared with the dutyholder.
I judge that HYB is managing its organisational capability adequately to maintain nuclear safety. Specifically, through sampling and targeted discussions at all levels in the organisation, I judge that HYB :
- Has an adequate understanding of its existing organisational capability and is proactively managing its short-term risks
- Is complying fully with NGL’s arrangements for the management of change and its governance and oversight
No significant issues were found in the station’s implementation of NGL’s LC36 arrangements, I have, therefore, rated the inspection green against LC36