Executive summary
Date(s) of inspection:
May 2023Aim of inspection
EDF Nuclear Generation Limited (NGL) is making a series of staff reductions at Hinkley Point B (HPB) following end of generation at the station in 2022. These changes are set out in an overarching Management of Organisational Change (MOC) proposal (HPB/MOC/430, 14 November 2022, 2023/5275) and supporting department level enacting MOCs (2023/13508). They comprise an overall reduction in staff from 474 FTE (as at August 2022) to 373 FTE (Reactor 4 Fuel Free Verification - nominally Q1/2024).
ONR is applying a flexible permissioning approach to these changes, specifically enhanced implementation monitoring and control (EIM&C), as set out in permissioning record PR-01242, which targets the changes taking place in the HPB Maintenance department in 2023 (release of 7.4 FTE maintenance technicians). Regulatory issue RI-11332 has also been raised to seek evidence for completion of relevant enabling actions for the reductions in the Engineering department (release of 7 FTE engineering staff).
This inspection supports ONR's flexible permissioning approach to the organisational changes taking place during defueling of HPB in 2023. Its main aim is to test the adequacy of HPB's control of the organisational changes taking place in Maintenance and Engineering departments, as per the requirements of LC36(2).
Subject(s) of inspection
- LC 10 - Training - Rating: GREEN
- LC 12 - Duly authorised and other suitably qualified and experienced persons - Rating: Not Rated
- LC 36 - Organisational capability - Rating: GREEN
Key findings, inspector's opinions and reasons for judgement made
Key findings, inspector's opinions and reasons for judgements made. As regards the Maintenance department organisational changes, the station explained that it will not now release the maintenance technicians in Step 2 until 2024. However the station could explain how it will meet the four criteria for release of these technicians, as set out in Management of Organisational Change (MOC) proposal HPB/MOC/461. The station could also evidence progress with completion of the training of the new maintenance technicians, including completion of knowledge checks and application of exemptions. I advised the station that I will hold the regulatory hold point for release of the maintenance technicians (PR-01242) open until the station can evidence the corresponding reduction in workload.As regards the Engineering department organisational changes, it is clear that the station is carrying significant vulnerabilities in this department, however these vulnerabilities concern potential delays to implementation of the Management of the Asset (MotA) programme rather than immediate challenges to safety on the site. Action is being taken to mitigate these vulnerabilities. The station could provide adequate evidence for completion the enabling actions for release of staff in Step 1 of the Engineering Department organisational changes, except in one case concerning a system handover where the handover had not been fully completed. This was self-identified and the station will raise a condition report to ensure the necessary corrective action is taken. On the basis of the evidence seen, I was satisfied that the open regulatory issue (RI-11332) on the Engineering department changes can be closed.
I examined the internal oversight and assurance processes being applied by the station to control the organisational changes during defueling, including the role of the Independent Nuclear Assurance team. I was satisfied that these processes are being applied with adequate rigour, in accordance with the licensee's arrangements.
Conclusion of intervention. I conclude that the station is implementing adequate arrangement to control the organisational changes taking place in the Maintenance and Engineering Departments during defueling. I have therefore rated the inspection 'Green' (no formal action) against Licence Condition 36. I also conclude that the station is is implementing adequate arrangements for the training of new Maintenance Technicians. I have therefore rated the inspection 'Green' against Licence Condition 10. I have not provided a rating against Licence Condition 12 as this was not the main focus of the inspection, however there was no indication of non-compliance with this licence condition.
Conclusion
I conclude that the station is implementing adequate arrangement to control the organisational changes taking place in the Maintenance and Engineering Departments during defueling. I have therefore rated the inspection 'Green' (no formal action) against Licence Condition 36. I also conclude that the station is is implementing adequate arrangements for the training of new Maintenance Technicians. I have therefore rated the inspection 'Green' against Licence Condition 10. I have not provided a rating against Licence Condition 12 as this was not the main focus of the inspection, however there was no indication of non-compliance with this licence condition.