- Site: N/A
- IR number: 21-087
- Date: October 2021
- LC numbers: 17, 36
Executive summary
Purpose of intervention
This was a planned Licence Condition (LC) inspection of EDF’s Technical Client Organisation (TCO), and Technical Support Organisation (TSO) nuclear baselines and management arrangements, carried out from 11 - 14 October 2021 at EDF Barnwood. The inspection was undertaken in accordance with the ONR Operating Facilities Division Integrated Intervention Strategy for 2021/22.
The TCO is a joint set of arrangements between two Licensee organisations (EDF Nuclear Generation Ltd (NGL) and EDF NNB Generation Company Ltd (NNB)) and the TSO, a business unit made up largely of technical specialists, which is wholly owned by EDF Energy. They have agreed to act collaboratively to address the development of skills and resolution of technical challenges through a common strategy. Each licensee retains its own set of LC compliance arrangements.
Purpose of Intervention
The main purpose of the inspection was to conduct a rated LC36 (Organisational Capability) and an unrated LC17 (Management Systems) inspection of EDF’s TCO and TSO. The aim was to focus on the implementation of NGL’s licensee arrangements in the context of the TCO collaboration. This was a follow-up to a previous ONR inspection of the TCO in November 2020.
ONR guidance was used to assess the organisational capability and management system.
Interventions Carried Out by ONR
The intervention was carried out jointly by ONR Leadership and Management for Safety and Quality and Supply Chain Inspectors and NGL’s Internal Nuclear Assurance lead for Organisational Capability.
An information pack was provided by NGL, including the current organisational baseline for NGL’s Central Services Function (CSF). The information was examined prior to the inspection. During the inspection, a range of personnel were interviewed, covering the topics listed below. They were selected to represent people working in NGL and those seconded to the TSO from NGL and NNB (from the Hinkley Point C (HPC) project). They included a cross section of personnel from the senior leadership to group leaders. This range of people provided the opportunity to understand the impact of the TCO’s implementation on the NGL CSF. The focus areas were:
- TCO/TSO Baseline: overview and management in the TCO context and interface between NGL and HPC/TCO and NGL
- Intelligent customer arrangements and implementation: interface with HPC
- Governance arrangements: overview and implementation
- Work planning and prioritisation: arrangements and implementation
- Management System Manual (MSM) development
- Quality Plans – sample the framework to produce quality plans and to sample working quality plans.
Explanation of Judgement if Safety System Not Judged to be Adequate
N/A – this was not a system-based inspection.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
Based on the sample of documents and the interviews with key personnel ONR judges that the current governance arrangement are working adequately given the maturity of the TCO. For this reason, ONR recommends a review of the arrangements at an appropriate point in the development of the TCO. For the organisation to develop and maintain the appropriate capability and capacity NGL’s strategy for transformation needs to be better defined. The definition of organisational and nuclear baselines was identified as an area for improvement, in particular, the approach to shared resources. NGL is aware of the need to make improvements and have put initiatives in place to address them Therefore, ONR will monitor NGL’s progress through routine regulatory engagements.
Based on the evidence examined and the interviews conducted the MSM, ONR is of the opinion that this is a high-level document containing most of the information required for the TCO to be run effectively and is adequate for the early stages of maturity. The arrangements work partly because of the existing relationships between NGL staff in the CSF and those seconded into the TSO. Areas for improvement have been identified in the Intelligent Customer and Quality Assurance arrangements. This inspection was not rated but was used to gather data to support a follow-up LC17 inspection in due course. These areas will be monitored through routine regulatory oversight.
Conclusion of Intervention
At this stage of development of the TCO we judge that the rating of LC36 as GREEN is appropriate. The LC17 inspection was not rated.