The strategy of closure

30 October 2001

The British Government has, through its Health and Safety Executive, published a report on its review of the strategy of British Energy for decommissioning its nuclear licensed sites.

The review of British Energy’s strategy for the decommissioning of its seven AGR power stations: Dungeness B, Hinkley Point B, Heysham 1 and 2, Hartlepool, Torness, and the Sizewell B PWR, considered the technical and some financial aspects. The review compared BE’s strategy with national and international guidance, and considers the underlying assumptions made and whether the plans submitted are comprehensive and appropriate.

The audit was undertaken by the Nuclear Installations Inspectorate (NII) in 1999, and its findings were published in January 2000. NII made 103 recommendations for action by BE, aimed at ensuring that BE maintained or improved the capability to discharge its responsibility as a nuclear site licensee. The Health and safety Executive (HSE) has produced a report on the progress to date.

Key findings of the review include:

• Overall, NII regards BE’s strategy to be appropriate at this time, being consistent with both national and international guidance and flexible enough to accommodate lessons learned from other licencees.

• NII considers the technical aspect of BE’s proposals to be practicable, feasible and realistic and, on the basis of information presented, proposals for timing of final dismantling, which have been reduced to 85 years after cessation of operations, are reasonable. NII will seek further evidence on justification for timing the final dismantling before the next review.

• BE’s management plan for decommissioning and its implementation plan need further development. NII would not expect these plans to be fully developed yet, but will expect progressively more detail as the end of generation and the start of decommissioning approaches.

• Proposals for Sizewell B are less well developed than those for the AGR fleet. This is not inreasonable, as decommissioning is not scheduled for another 35 years and NII will monitor plans for Sizewell B regularly as part of the review process.

• BE has a soundly-based process for establishing the cost of decommissioning, but some of the base costings are now rather dated. NII expects BE to have revised its costing base by the time of the next review.

Of the 103 recommendations, six have been formally closed-out, although NII says that this is not a true reflection of the amount of work that has been made towards resolving the concerns that were raised in NII’s original report.

NII always expected that the closing-out recommendations would take time to achieve. The rate of progress at this stage, in terms of the number of recommendations that have been closed-out, is not unexpected and is comparable with other major NII audits and team inspections.

Given the need to demonstrate the success of changes and improvements in key areas and for NII to review the evidence of achievement, close-out of all 103 recommendations is unlikely to be achieved until well into 2002.

Laurence Williams, Chief Inspector for NII, said: “The management of safety is essential for continued operation of BE’s power stations. NII’s audit of the company’s safety management systems in 1999 showed that improvements were necessary. We expected it would take time to implement all 103 recommnedations. We gave BE time to bring their systems up to the required standard. Although progress has been slower than we would have liked, it has not been unreasonable. We have made it clear that we will not sanction any further reductions in safety-related staff until the audit findings are satisfactorily closed-out. Principally, we will be looking to BE to demonstrate adequate progress in managing change and controlling resources and commitments. Overall, BE has made good progress, but we do not envisage close-out of all 103 recommendations much before the end of 2002. Meanwhile, NII will continue to monitor closely operations at the power stations and at the company’s headquarters to ensure safety is maintained.

“NII has had very good cooperation from BE throughout the review, and I am particularly pleased at the agreed reduction in decommissioning timescales from 135 years to 85 years after the end of operation. On the basis of the information we now have about the likely availability of a radioactive waste disposal site and the national priorities for the use of such a site. NII believes that 85 years is a realistic timescale.”

Action areas

Key areas for licensee action that arose from the audit in January 2000 were:

• BE to stop the planned reduction of in-house staff numbers until it can demonstrate its forward work predictions are reliable, and that the Management of Change processes will not adversely affect the safety of nuclear plants.

• BE must ensure its business plans match the in-house staff capability and perceived work load.

• BE is to develop policies to identify the key considerations and guide decision making on why, when and how to use contractor resources, including their ‘intelligent customer’ requirements.

• BE is to investigate the reasons for the high level of overtime worked in certain areas, and take steps to prevent excessive hours being worked by staff handling nuclear safety related work.

• BE has to critically review its Management of Change processes in order to ensure they will incorporate the lessons learned from the change process.

Close-out process

There are three stages to close-out:

• Stage 1. The licencees develop proposals for implementation, and initial interactiuons with NII take place regarding the scope of work.

• Stage 2. The licencees complete their work and submit responses to recommendations, with evidence of achievement, for NII to assess and decide upon close-out status.

• Stage 3. Follow-up work and/or monitoring required by the licencees or NII to achieve full close-out.

The initial stage involves the licencees in developing proposals and solutions to resolve the problems identified by the audit. During stage 1, NII liaises with the licencees’ teams to ensure that the pertinent issues are being addressed for each recommendation and that, if developed and implemented properly, the proposals are likely to satisfy the recommendations. Because the licencees are developing proposals at this stage, NII does not undertake any detailed assessment. If there are no significant concerns or shortfalls identified in the scope of the licencees’ proposals, NII indicates that the process may move into stage 2.

In Stage 2, the licencees fully develop their proposals and complete the necessary work for each recommendation. When the work has been completed for a specific recommendation, and any related changes to working practices have been implemented, a response to the recommendation can then be submitted to NII with the evidence of achievment. The response also needs to identify what measures the licensee has in place to demonstrate the effectiveness of an improvement, including any additional security to be undertaken during the bedding in phase. NII assesses this submission, and forms a judgement with regard to close-out.

Where interim close-out is granted, the process moves to Stage 3. This will encompass work by NII and/or the licencees. Where licencees are applying additional security to demonstrate to themselves that an improvement has been effective and the benefits realised. NII is likely to include this in Stage 3, and await the result of the licencees’ work. If the results are satisfactory, this could provide an adequate basis for close-out. Upon successful completion of Stage 3, recommendations will achieve full close-out.

Progress to date

So far, 6 out of the 103 recommendations have been closed-out, and a further 7 have been submitted to NII for close-out assessment. This rate of progress was expected.

In addition, 46 recommendations have moved into Stage 2, and NII awaits the submissions when the work is complete and changes have been implemented. There are 14 recommendations still in Stage 1, and NII has yet to see an initial Stage 1 proposal on the remaining 30 recommendations.

Reduction of staff numbers

The audit report identified the need for the licencees to stop further planned reductions in staff until they could demonstrate that forward load predictions were reliable and that the flaws in the management of change process had been addressed. The licencees have put in place new processes for both work planning and management of change. However, the processes need to be proven before the audit recommendations are closed-out.

NII recognises that changes need to be allowed to take place to demonstrate that the management of change process is working effectively, but this must be done in a controlled manner. A way forward on staff reductions is under discussion. This places change proposals into one of three types: not safety-related; safety-related but not involving downsizing; and safety-related with downsizing. Only the latter type of change – safety-related with downsizing – would be affected.

A key aspect of the way forward is for the licencees to collate information on such proposals and to present NII with an overall indication of their intended structure and resources. NII is awaiting the licencees’ provision of the necessary information. Until the way forward has been confirmed, or the licencees present a satisfactory alternative, the hold on further staff reductions in safety-related areas should remain in place.

Work load

The licencees have stated that, since the audit, they have achieved the work load reductions upon which their original staff reduction targets were predicated. They have also implemented changes aimed at better matching the work load to the available in-house resources. The improvements include a new process for categorisation and prioritisation of work, with the highest priority being applied to work necessary to maintain safe operation.

The revised work planning process has been applied in the business planning round for the current year. The demonstration of its success, including the ability to successfully manage emergent work, prioritisation and resource pinch points will take time and will be factored into the close-out requirements for the relevant audit recommendations.

Recording the skill base

This was a key area covered by the audit, and generated several recommendations. In response, the licencees have conducted a ‘grass roots’ review of their skills requirements. This has led to the introduction of a uniform process for setting down the range of skills required within the licencees’ technical centres, and the criteria to be met for the appointment of suitably qualified and experienced people.

This process generates a register which identifies the different technical roles and the staff qualified to undertake work in each area. To address NII’s concerns over vulnerabilities to loss of staff in key areas, the process requires specific consideration, including contingency plans, and senior management approval where there is limited coverage. The licencees are also seeking to recruit staff in key areas of expertise.

Policy for use of contractors

NII is not opposed to the use of contractors. However, their use must not undermine the licencees’ ability to fulfill their responsibilities in law. The concerns raised in the audit highlighted the lack of a clear policy on the use of contractors and the lack of guidance on factors to be considered from a licencees’ perspective. Both aspects have been addressed. The licencees have put in place a policy statement setting out the main principles governing the use of contractors.

The procedure sets out the key steps in the decision-making process for judging whether or not use of a contractor is appropriate. This includes specific consideration of reasons why a contractor should not be used, such as the need to maintain in-house technical capability or where the loss of the contractor’s services could jeopaardise the licensability of BE.

If use of a contractor is judged to be appropriate, and prior to the contract being let, the procedure requires an internal resource plan to be produced to ensure there are adequate resources available within the licensee to manage the contract. There are also new requirements with respect to receipt of work from contractors to ensure there is an in-house technical review and owndership by the licensee.

Excessive working hours

In response to NII’s concerns over excessive working hours, the licencees took action to instruct staff with guidance on what should be included.

The licencees report a greater awareness among staff regarding the need to record all hours worked. In addition, there is clearer accountability through the line management for ensuring staff record their working time properly, and that working hours are monitored regularly and appropriate action is taken where individual work loads are high.

The future

BE has already undertaken a considerable amount of work to address the recommendations arising from the NII safety management audit. The issues raised by the audit have needed careful consideration by the licencees and the development of effective solutions.

In response to the audit, the licencees have developed new or improved ways of working. A key requirement for closing-out recommendations is that the licencees must provide evidence of achievement. They must also identify what measures have been put in place to demonstrate the effectiveness of changes or improvements.

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