- Site: Hartlepool
- IR number: 21-142
- Date: December 2021
- LC numbers: 36
Executive summary
Purpose of Intervention
This was a planned inspection of EDF Energy Nuclear Generation Ltd.’s (NGL’s) Hartlepool (HAR) 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 Hartlepool (HAR) Integrated Intervention Strategy (IIS) for 2021/22.
Purpose of Intervention
The purpose of this intervention was for ONR to form a view on the adequacy of HAR’s Licence Condition 36 (LC36) arrangements for maintaining SQEP resource and their process for managing organisational change. The inspection was conducted on-site – 30 November and 1 December 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 and that the management of organisational change is being controlled adequately.
The inspection was conducted by one specialist Leadership and Management Safety inspectors, ONR’s HAR nominated site inspector, supported by one nuclear associate. It was performed in line with ONR’s guidance (as described in our technical inspection guides.
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, 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.
We identified that the organisational capability of the Performance Improvement (PI) Department is not adequate. This has a latent impact on nuclear safety due to lack of competent resource with the capacity to both implement the corrective action programme process and manage and deliver training.
Except for the PI Department, we consider that the Station’s organisational capability is 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).
We found that each of the station management of change (MoC) assessments carried out in 2021 contained shortfalls and the majority fell significantly below the expectations of NGL’s own LC36 arrangements, 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 arise from shortfalls in NGL's MoC arrangements (identified previously in RI 8500) and associated training.
We also identified potential shortfalls in the governance and oversight of organisational capability at both site and Fleet level.
Conclusion of Intervention
Based on the evidence sampled, I judge that HAR 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).
Further, based on the evidence sampled during this intervention and the Hinkley Point B LC36 compliance inspection on 16/17 November 2021, I conclude there to be significant shortfalls in NGL’s LC36 organisational capability arrangements against identified RGP. I judge that the shortfalls in NGL’s LC36 arrangements have given rise to systematic compliance shortfalls.
Recommendations
It is recommended that:
- Two new Level 3 Site regulatory issues (RIs) be raised to:
- Justify the adequacy of the Performance Improvement department.
- Implement adequate management of change.
Due to the consistency in findings at both the HPB LC36 inspection and this inspection, 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 in twelve months. In the meantime, I will track NGL’s progress in addressing these issues by:
- Observing HAR’s MoC Steering Group;
- Observing the Fleet People Delivery Team; and
- Fleet Level 4 regulatory interface meetings.