Executive summary
Date(s) of inspection: May 2024
Aim of inspection
Licence Condition 36 (2) requires the licensee to make and implement adequate arrangements to control any change to its organisational structure or resources which may affect safety. NRS Dounreay have recently started to implement their “Fit For the Future” organisational change programme. The purpose of this intervention is to consider whether / how the implementation of this organisational change is impacting site safety.
Further, the inspection will consider Dounreay’s safety culture and to understand work to develop an improved working culture following previous commitments made to ONR.
Subject(s) of inspection
- LC36 - Organisational capability - Rating: Not rated
Key findings, inspector's opinions and reasons for judgement made
This was a planned Licence Condition (LC)36 (Organisational Capability) compliance inspection. It was conducted by ONR’s site inspector, an ONR specialist in leadership and management for safety and a developing inspector against relevant good practice in ONR inspection guide on the management of organisational change.
The scope of the inspection was provided in advance. The aim of the inspection was to consider the status of the implementation of the management of change (MOC) proposal for Dounreay's Fit for the Future (FFF) programme. FFF introduces a programmatic approach to the site. Implementation of the MOC commenced on 1 April 2024.
I interviewed personnel in key roles across several areas of the new organisational structure. We discussed the status of the implementation plans and the scope of the new roles. We visited two operational areas for informal discussions on the impact of the change with supervisors, operational personnel and safety representatives. I examined a sample of implementation plans and competence assessments.
I found that implementation is at an early stage. Governance arrangements have been put in place. For example there is a Change Steering Board, and the Transition Team continues to manage the change. Implementation plans have been developed, however, levels of maturity vary as some parts of the organisation, such as Services, were developed later than others. There was a good understanding of the purpose of the change and buy-in from leaders. There was less certainty from supervisors and operators.
We conducted part of the inspection on a day of industrial action for the site. Despite the logistical challenges this represented we had access to relevant personnel and the conversations were open and honest. Minimum manning levels for safe and secure operations were maintained throughout.
I judge that implementation is an early stage, as it is six weeks since the new structure was enacted. We had open and honest discussions and I provided advice on many aspects of the implementation, which will be followed up with regulatory advice. It was decided not to rate the implementation. Instead, we will follow up on aspects of the implementation through on-going engagements and future inspections.
Conclusion
I judge that implementation is an early stage, as it is six weeks since the new structure was enacted. We had open and honest discussions and I provided advice on many aspects of the implementation. It was decided not to rate the implementation. Instead, we will follow up on aspects of the implementation through regulatory advice, on-going engagements and future inspections.
I recommend that future ONR interventions focus on:
- Recruitment, retention and succession planning to fill key vacancies in the new structure.
- The implementation of the L1, 2 and 3 assurance arrangements.
- The development of the Heads of Profession in supporting capability development and career pathways for key capabilities.
- The Head of Professional role for Decommissioning Operations in supporting operational capability with a focus on the recruitment, retention and training of the ATO holders.
- Development of the services organisation and it's relationship to Balance of Site.
- Monitoring the minimum safety and security requirements during any potential industrial action including the surrender of voluntary roles.
I recommend that we conduct quarterly L4 meetings to monitor progress and provide regulatory oversight of the areas of focus. I also recommend that we conduct an assessment of the assurance arrangements in approximately 12 month's time.