Date(s) of inspection
- December 2023
Aim of inspection
The purpose of the inspection was to check the capability, governance and management arrangements for the EPR Programme.
The EPR Programme is a mechanism to provide services between NNB Generation Company (HPC) Ltd (NNB GenCo) and Sizewell C Ltd (SZC Ltd), across six functional areas: human resources, information technology, legal, supply chain, project management office and quality.
The EPR Programme was developed jointly by NNB GenCo and SZC Ltd under their management of change processes. The first phase was implemented in a phased approach in 2023 across the six functional areas and a post-implementation review was conducted in November 2023.
It is important to nuclear safety that both NNB GenCo and SZC Ltd have sufficient resources to deliver their responsibilities; and the EPR programme is a mechanism that allows both companies to share a pool of resources to fulfil their responsibilities.
Subject(s) of inspection
- LC36 – Organisational capability – Rating: Green
Key findings, inspector’s opinions and reasons for judgement made
ONR’s inspectors gathered evidence by examining relevant documentation and records and conducting interviews with key personnel near the end of the first phase of the EPR Programme.
The inspectors focused on:
- the capability of the EPR Programme to provide the required level of service where it could impact safety;
- the governance and management arrangements in place to oversee and control service provision; and
- the future development of the EPR Programme as it moves to a standalone organisation.
ONR found that phase 1 implementation has been properly managed. The services are being provided through adequate arrangements with appropriate governance. In phase 1, certain staff working for NNB GenCo and SZC Ltd in the six functions have been allocated to the EPR Programme and their employment status remains unchanged; there is no separate company that employs them. Both NNB GenCo and SZC Ltd retain some staff within each function that make decisions for each of them as a client. These people are not allocated to the EPR Programme. They act as intelligent customers for NNB GenCo or SZC Ltd.
Future phase 2 implementation requires further strategic thinking. The scope of phase 2 and a road map for its delivery were yet to be developed. NNB GenCo and SZC Ltd intend to create a company to deliver the shared services. Creating this company as a legal entity should be straightforward, but developing its arrangements so that nuclear safety capability is secured will require time and effort.
Based on the current position, this inspection was rated as green: relevant good practice was generally met and no significant shortfalls were identified in the current delivery of safety at phase 1. ONR will continue to monitor phase 2 via a regulatory issue.