69. The objective of the audit was to establish whether the resources and the overall capabilities of BEGL and BEG(UK)L were such that they could continue to discharge their responsibilities as nuclear Licensees in the light of their staff reduction programmes. The findings are based on the information we obtained from confidential interviews with a wide cross section of the staff within BEGL and BEG(UK)L, focused upon the headquarters and technical centres at Barnwood in Gloucester (BEGL) and Peel Park in East Kilbride (BEG(UK)L, and in key contractors.
70. The audit has identified issues which could impact on the licensability and safety performance of BEGL and BEG(UK)L unless effective corrective actions are taken. The report focuses on the areas for action to ensure the capability of BEGL and BEG(UK)L to discharge their responsibilities as Licensees is maintained or improved. However, we have also identified aspects of good practice or characteristics of the type we expect from nuclear Licensees.
71. The overriding issue is the lack of a clear definition of the requisite skills base that must be retained within both BEGL and BEG(UK)L to fulfill their responsibilities as Licensees. This is combined with the absence of formal policies covering the use of contractors to provide technical resources and expertise, in particular to define the extent to which reliance upon contractors is allowable.
72. There are related issues which include the need for a long term strategy to ensure retention and development of the expertise required within the Licensees throughout the lifetime of the nuclear power stations (including decommissioning). Also, there is a lack of formal and viable contingency plans to address the Licensees' vulnerability to loss of key contractors.
73. The management of change process in both Licensees is in need of urgent review. In each Licensee there are flaws in both the process and in its application. For example, the change process has not prevented the creation of areas of singleton expertise, which makes both Licensees vulnerable to loss of key individuals. There are also cases where staff have been released without the necessary prerequisites having been achieved (eg a reduction in work, or the provision of a suitably qualified and experienced replacement).
74. A reduction in work load was a principal factor in the downsizing aims of both Licensees. However, forward predictions of the work load (taking into account emergent work) is difficult to achieve accurately. The staffing level targets in both Licensees and their management of change process need to recognise this uncertainty.
75. There are issues to be resolved before the proposed integration of the management and technical teams in BEGL and BEG(UK)L could be agreed by NII. The primary issue is the ability of each Licensee to demonstrate it will retain control of its operations, as required under the nuclear site licences. The additional work load and responsibilities placed upon staff are part of the issue.
76. The key areas for action by the Licensees are as follows (the specific recommendations are presented in Appendix 3):
77. We judge that the issues raised, whilst significant over the medium to long term, are not such that they challenge the immediate safety of the operating stations.
78. BEGL and BEG(UK)L are producing action plans to address the recommendations arising from the audit. These action plans are to be completed within four weeks of receipt of this report. We will progess this work with the two Licensees to expedite a satisfactory resolution of the recommendations.
79. The commercial pressures on BEGL and BEG(UK)L will remain, if not increase. Both Licensees will need to remain aware of the issues raised in this report and their need to have an adequate management structure and sufficient of their own resources to discharge the obligations and liabilities associated with the holding of a nuclear site licence.
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