- Site: Hinkley Point B
- IR number: 21-128
- Date: November 2021
- LC numbers: 36
Executive summary
This was a planned inspection of EDF Energy Nuclear Generation Ltd.’s (NGL’s) Hinkley Point B (HPB) Power Station, undertaken as part of the planned intervention strategy for the Operating Facilities Division (OFD) of the Office for Nuclear Regulation (ONR). It was carried out in accordance with the planned inspection programme contained in the HPB Integrated Intervention Strategy (IIS) for 2021/22.
Purpose of Intervention
The primary purpose of this intervention was for ONR to form a view on the adequacy of HPB’s Licence Condition 36 (LC36) arrangements for maintaining suitably qualified and experienced resource and their process for managing organisational change. The inspection was conducted on-site – 16, 17 November 2021.
Interventions Carried Out by ONR
The inspection comprised both the review of documentation plus on-site interviews and discussions to gain assurance that there are sufficient human resources to maintain nuclear safety while adequate preparations are made for end of generation and that the management of organisational change is being controlled adequately. It also sought to gain an understanding of the station's current safety culture.
The inspection was conducted by two specialist Leadership and Management Safety inspector and ONR’s HPB nominated site inspector. The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.
Explanation of Judgement if Safety System Not Judged to be Adequate
This is not applicable to this intervention as no system-based inspection was undertaken.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
Site Licence Condition 36 – Organisational Capability
A suitably underpinned baseline organisation, which is understood by the licensee on site, is fundamental in allowing changes in organisation to be assessed and categorised effectively. Consideration of the 2020 annual baseline statement identified that the licensee could not provide a justified baseline organisation. In part this is due to non-compliance with NGL’s extant LC36 arrangements. It is my opinion, however, that there is an inadequate level of competence in all organisational capability process role holders that I consider to arise from shortfalls in NGL's organisational capability arrangements and associated training packages.
I consider that the Station’s organisational capability to be adequate to meet current nuclear safety requirements through a combination of management action and staff prioritisation of work. Even so, the organisational capability is under significant stress and it is my opinion that, as the station moves from operations into defuelling, there needs to be better control and alignment with relevant good practice (RGP) in this area.
I found inconsistencies in the application and implementation of NGL’s management of change (MoC) arrangements. Assessments carried out in 2021 ranged from good practice to non-compliance with company arrangements and many fell below ONR guidance and RGP. None of the MoC process role holders interviewed demonstrated sufficient understanding of the requirements and expectations of the LC36 process. In mitigation, however, they were able to describe the basis of the change and the underpinning logic. It is my opinion that there is an inadequate level of competence in all licensee MoC process role holders that I consider arises from shortfalls in NGL's MoC arrangements and associated training.
I also identified potential shortfalls in the governance and oversight of organisational capability at both site and Fleet level.
Safety Culture Assessment
I found tensions regarding workloads, resource levels and loss of capability. These have been recognised by HPB leaders and are now being acted on. It is my opinion, however, that there is a misalignment between senior manager expectations of HPB personnel and the staff view of what HPB senior managers and leaders are delivering. The misalignment in expectations of trust between senior management and the workforce is leading to tensions that, if left unchecked, have the potential to impair safety culture at HPB.
We identified that performance monitoring for both safety culture and organisational capability needs to be reviewed to ensure monitoring arrangements keep pace with the changes underway at HPB. This was acknowledged by HPB Human Resources personnel, who cited plans for introducing new monitoring measures by April 2022.
Conclusions of Intervention
Site Licence Condition 36 – Organisational Capability
Based on the evidence sampled, I judge that HPB has significant shortfalls in the implementation of NGL’s arrangements for compliance with LC36. In accordance with ONR’s guidance on inspection ratings, I have assigned an inspection rating of Amber (Seek Improvement).
I consider the shortfalls identified are likely to be manifestations of systemic issues rather than station specific. This view has been reinforced by the findings from the LC36 inspection conducted at Hartlepool on 30 November and 1 December 2021.
Due to the systemic nature of the shortfalls identified, it is recommended that two new Level 3 Fleet RIs be raised to:
- Justify the adequacy of the nuclear baseline.
- Implement adequate organisational capability and management of change arrangements.
A follow-up LC36 compliance inspection will be conducted shortly after HPB has ceased power generation (in nine to twelve months). In the meantime, I shall track NGL’s progress in addressing these issues and verify potential shortfalls in both Site and Fleet governance and oversight of organisational capability.
Safety culture
The safety culture aspects of this intervention were not rated as the intervention was used for fact-finding purposes and to inform future end of generation safety culture interventions.
Overall, staff at all levels within the HPB organisational structure portrayed a stable but fragile safety culture where staff are committed to maintaining safety standards on site, particularly nuclear safety standards. Addressing the tensions described is key to maintaining and strengthening safety culture from the current fragile state.