Executive summary
Date(s) of inspection: September 2024
Aim of inspection
EDF Nuclear Generation Limited (NGL) is carrying on defueling of Hinkley Point B (HPB) station following end of generation at the station in 2022.
HPB is also planning a new organisational structure in support of its deconstruction project following the planned fuel free verification.
The aim of this inspection was to examine whether HPB is maintaining adequate organisational capability during defueling as per the requirements of LC36.
LC36(1) requires the licensee to ‘provide and maintain adequate human resources to ensure the safe operation of the licensed site’. LC36(2) requires the licensee to 'make and implement adequate arrangements to control any change to its organisational structure or resources which may affect safety'.
Subject(s) of inspection
- LC 36 - Organisational capability - Rating: GREEN
Key findings, inspector's opinions and reasons for judgement made
From the evidence sampled by the inspection team I found that Hinkley Point B (HPB) is in a dynamic situation in managing its organisational capability for safe defueling of the station. The key reasons are as follows:
- The end of electricity generation naturally creates uncertainty about future job opportunities at the site.
- There is an ongoing risk of losing key personnel to the Hinkley Point C (HPC) new build project and other attractive employers in the area.
- Delays with Management of the Asset (MOTA) programme and defueling cause some frustration among personnel.
However, I found that HPB is maintaining adequate resources for safe operation of the site and has made and implemented adequate arrangements to control any change to its organisational structure or resources which may affect safety. The key elements of these arrangements are as follows:
- There is a robust Organisational Capability Steering Group in place that oversees management of all organisational changes.
- A realistic and justified reference nuclear baseline (aligned to the defueling organisational structure) is now supported by use of an Organisational Capability Risk Assessment (OCRA) tool.
- Independent Nuclear Assurance is providing a healthy challenge, to which the site is responsive.
- Departmental management owns, understands and adequately manages their resourcing risks. The managers demonstrate a positive attitude, lack of complacency and willingness to learn.
- HPB can and does safely stop the defueling operation on the days when there are not sufficient resources available for a shift.
- HPB appears to have ultimate control over releasing its people to the HPC site. The HPB HR team has created an optioneering document that provides a range of available release options to be discussed in relation to HPC job offers. As a result, rolling 12 month voluntary turnover has stayed very low.
- HPB is proactively preparing what-if scenarios for the worst case organisational capability risks.
Overall, there was notable improvement in the recent period following the recruitment of new HR Manager in May 2022.
Conclusion
Overall, based upon the judgements described above, I have concluded that an inspection rating of GREEN is appropriate for Licence Condition 36 – Organisational Capability.