This Appendix presents a list of all the recommendations arising from the audit process. The listing is as follows: Recommendations for BEGL; Recommendations for BEG(UK)L; Recommendations on Integration; and Recommendations from the Conclusions. For BEGL and BEG(UK)L, the recommendations are grouped under the subject areas of: Corporate Management Aspects; Management of Safety; Use of Contractors; and Divisional Findings. The latter comprise recommendations associated with specific areas of each Licensee's organisation.
BEGL to review its approach to communicating policy and strategy to staff to ensure that messages are received, understood, and acted upon.
BEGL to ensure members of BE Group who influence strategic direction in areas which impact on nuclear safety are suitably knowledgeable on nuclear industry requirements and standards.
BEGL to review the organisational management philosophy to ensure that safety related tasks are being carried out effectively.
BEGL to reconsider the decision to disband the Projects and Station Support Branch and provide a clear justification of any subsequent decision including proposals for the strengthening of the management of safety related projects.
BEGL to formalise, record and resource the skills base that it requires to underpin the duties of a Licensee to retain ownership and control of its operations.
BEGL to develop and promulgate a policy and guidance on the retention of safety related expertise required to discharge its responsibilities under the Licence.
BEGL to put in place the necessary arrangements to ensure that key expertise and corporate knowledge is retained within the organisation.
BEGL to review the succession planning process and demonstrate that it can maintain the supply of suitably qualified and experienced personnel, taking account of future needs, age profiles and the technical specialisms required.
BEGL to reinforce the requirement that overtime recording is mandatory for all staff at all levels, monitor compliance with the requirement, and act on the outcomes.
BEGL to investigate the reasons for the high level of overtime worked in certain areas (including estimates of that not reported), and take steps to prevent excessive hours being worked by staff handling nuclear safety related work.
BEGL to ensure that business plans are matched to the in house staff capability and work load.
BEGL to reconsider the options for the recognition of the value and reward of specialist expertise to ensure career paths for specialists remain attractive.
BEGL to demonstrate that the training strategy ensures the balance of training between the centre and the stations is appropriate. Recommendation 14 : As a matter of urgency, BEGL to critically review the Management of Change process in order to ensure it will incorporate the lessons learned from the change process thus far (including the findings from this audit). Recommendation 15 : BEGL to stop the planned reduction of in-house staff numbers until it can demonstrate the forward work prediction is reliable, and demonstrate that the new Management of Change procedure will not adversely affect the safety of nuclear plants. Use of Contractors Recommendation 16 : BEGL to develop and promulgate a policy to identify the key considerations and to guide decision making on why, when and how to utilise contractor resource.
BEGL to reconsider its philosophy for the use of Agency staff and the arrangements for the maintenance of their technical skills.
BEGL to review the performance of recent contracts and the process for dissemination of contract performance as part of the development of the policy on use of contractors.
As part of the work on developing a policy on the use of contractors, BEGL to review the type of work that can be handled by partners and the arrangements for direction and monitoring of such work.
BEGL to review its dependency on contractor support in specialist technical areas and derive formal contingency plans to secure that support against events such as contractors ceasing to trade, change of ownership and withdrawal of services.
As part of the development of the policy on the use of contractors, BEGL to reconsider the induction and refresher training required by contract staff.
As part of the work to support the development of the policy on use of contractors, BEGL to initiate a formal procedure for routine checking of a sample of the quality of contractors.
BEGL to consider the benefits of involvement in the industry wide initiatives relating to use of contractors (eg recording of contractor performance).
BEGL to develop and document procedures which ensure the contract strategy covers all safety aspects.
BEGL to reverse the trend to use contractors for safety related activities and increase the in-house staff levels in the Structural Assessment Group to ensure adequate control and ownership of the work.
BEGL to address the current vulnerabilities in the Materials Group regarding the areas of singleton expertise and current skills shortages, and provide longer term plans to sustain the key skill areas.
BEGL to address the current skills shortages in the NDT Group and provide longer term plans to sustain the key skill areas.
BEGL to clearly define the necessary skills and experience for staff in the Safety Case Production Group, and to demonstrate a viable succession plan to sustain the work of the Group.
BEGL to urgently review the working of the partnership arrangement in the structural integrity area to ensure that the sub-contracting of work by the partner is appropriate and that all contractor staff are suitably qualified and experienced to undertake their assigned tasks.
BEGL to ensure sufficient time for mentoring new recruits is maintained in the work planning for existing staff.
BEGL to strengthen the resources in the Human Factors area and to provide a programme to undertake more proactive work in this field.
BEGL to ensure that staffing reductions under Vision 2000 do not diminish the operating experience feedback service provided to Engineering Division.
BEGL to define the minimum sustainable level of PWR expertise required to meet current and future nuclear safety requirements and to ensure that the number of suitably qualified and experienced staff is maintained at or above this level.
BEGL to clearly define the requirements for the civil engineering interface role within Engineering Division and to provide appropriate procedures and guidance to enable the 'intelligent customer' responsibilities to be fulfilled.
BEGL to ensure that the training and development provided to staff in partner contractors is commensurate with that provided to its own staff doing equivalent work, including the acquisition and updating of plant knowledge.
BEGL to put in place measures to ensure staff in partner contractors are as well informed as would be the case if work was undertaken within BEGL.
BEGL to allow time for, and encourage staff to participate in, research and development activities.
BEGL to strengthen the available expertise in the criticality, graphite and severe accident areas.
BEGL to formally define the range and level of expertise required to be an 'intelligent user' of all computer codes used in safety analysis work, and to ensure the necessary expertise is retained and developed within BEGL
BEGL to provide more resources on fire protection, including a review of the decision to abolish the post of company fire safety officer, and undertake more proactive work at nuclear stations.
BEGL to recover the in house capability for radiation chemistry expertise.
BEGL to clearly define the requirements for the electrical engineering interface role within Engineering Division and to provide appropriate procedures and guidance to enable the 'intelligent customer' responsibilities to be fulfilled.
BEGL to review the partnership arrangement for C&I support to define those tasks which should be carried out only by BEGL staff, and to ensure that control and ownership of work always resides with BEGL.
BEGL to provide a status report on the safety case management initiatives, including a review against the findings from the NII safety case inspection in 1997.
BEGL to increase the level of suitably qualified and experienced personnel available to the Periodic Safety Review area of work.
BEGL to provide an adequate level of PSA expertise within Engineering Division to meet current and future workloads, including the implementation of its forward strategy regarding the use of PSAs.
BEGL to ensure that HSED Assessment and Consents Branch is adequately resourced to undertake a full range of independent assessment and review activities, including maintaining an internal overview of the INSA process.
BEGL to formally define the requirements for staff to be suitably qualified and experienced in HSED Assessment and Consents Branch (in particular for the specific INSA posts).
BEGL to ensure sufficient staff are available to carry out the INSA process and monitor the use of contractors for technical support to the INSA process to ensure independence is not compromised. Recommendation 50 : BEGL to ensure that the quality and depth of the INSA examination is maintained.
BEGL to review the function of HSED site inspectors and ensure staffing levels in HSED Inspection and Standards Branch are sufficient to cope with the existing work load without the need for excessive amounts of overtime working.
BEGL to transfer the HSED role of monitoring the Management of Change process in Engineering Division from Inspection and Standards Branch to Assessment and Consents Branch, and provide the necessary resources.
BEGL to make a robust safety case for the proposal to integrate industrial safety inspection into the Occupational Health Group, prior to implementing the change.
BEGL to ensure that its radiological protection standards are maintained and, wherever practicable, improved and the necessary expertise to achieve this aim is retained within BEGL.
BEGL to ensure the Procurement Department has sufficient staff to discharge its role and responsibilities, principally with respect to the provision of added safety value and contractor performance monitoring.
BEGL to improve the dissemination of information on contractor performance.
BEGL to ensure the different contractual relationships and the interface requirements are clearly defined and are commonly understood and applied throughout BEGL.
BEGL to define the corporate QA strategy and the approach to the management of quality throughout BEGL covering the stations, Engineering Division, the corporate centre and contractors.
BEGL to ensure that the Corporate Quality Department is adequately staffed to implement and maintain the corporate QA strategy.
BEGL to define the role and influence of the Business Review and Audit Department (BRAD) and the main BE Board on its activities as a Licensee.
BEGL to ensure that a practicable solution to the problems regarding harmonisation of QA strategies, procedures and practices is identified prior to integration with BEG(UK)L.
BEGL to review the role and scope of responsibilities for the Emergency Planning Group to improve its ability to discharge the function of maintaining and improving standards of emergency response.
BEGL to ensure that the emergency response capability is not compromised by changes in the Information Management Department (IMD) and to put in place specific performance measures to monitor the impact of reductions in IMD staff.
BEGL to review the operational experience feedback process, and the role of the Central Feedback Unit, to ensure its effectiveness and to introduce measures to demonstrate its effectiveness.
BEGL to ensure (and demonstrate) that the Human Resource Department has the requisite level of staff to effectively perform its function.
BEG(UK)L to review its approach to communicating policy and strategy to staff to ensure that messages are received, understood, and acted upon.
In support of work on Recommendations 66 and 1, BEG(UK)L & BEGL to ensure that full integration and split site working will not adversely affect their communication systems and organisational culture.
BEG(UK)L to recover its full in house intelligent customer capability.
BEG(UK)L to review its policy and practice for the appointment of SQEPs to ensure an appropriate range of the necessary topic areas, sufficiency in numbers and coverage of all topics by direct employees of the Licensee.
BEG(UK)L to formally review and develop the SQEP register concept to identify criteria to be met before a person can be entered on the register and requirements for maintenance of skills.
BEG(UK)L to develop into a formal procedure the guidance for decision making on SQEP capability of candidates to include, inter alia, requirements for the situation where the Section Manager's technical discipline does not allow direct assessment to be made.
BEG(UK)L to develop the formal process of review of the SQEP Register to consider longer term requirements (say over 10 years) and maintain a sufficient number of suitably qualified and experienced staff.
BEG(UK)L to ensure that business plans are matched to the in house staff capability and workload.
BEG(UK)L to reinforce the requirement that overtime recording is mandatory for all staff at all levels, to monitor compliance and act on the results.
BEG(UK)L to investigate the reasons for the high level of overtime worked in certain areas (including estimates of that not reported), and take steps to prevent excessive hours being worked by staff handling nuclear safety related work.
As a matter of urgency, BEG(UK)L to critically review the Management of Change process in order to ensure it will incorporate the lessons learned from the change process thus far (including the findings from the audit).
BEG(UK)L to stop the planned reduction of in-house staff numbers until it can demonstrate the forward work prediction is reliable, and demonstrate that the new Management of Change procedure will not adversely effect the safety of nuclear plants.
BEG(UK)L to develop and promulgate a policy to identify the key considerations and to guide decision making on why, when and how to utilise contractor resource.
BEG(UK)L to review its dependency on contractor support in specialist technical areas and derive formal contingency plans to secure that support against events such as contractors ceasing to trade, change of ownership and withdrawal of services.
BEG(UK)L to produce arrangements for working with the satellite offices which clearly define and formalise the roles of the Licensee and the contractor.
BEG(UK)L to address the status of the Fuel Route Group, review the in-house resource levels and demonstrate there are adequate plans to retain and develop fuel route expertise.
BEG(UK)L to review the overall forward work load in the fuel route area to ensure adequate resources are available for safety related work.
BEG(UK)L to reconsider the competencies that must be retained within the Licensee in the Nuclear Technology Section and provide BEG(UK)L SQEP personnel to cover these areas of expertise.
BEG(UK)L to reconsider the procedures for acceptance of safety related work from contractors to ensure it receives an informed review by their SQEP personnel so that they can demonstrate control and ownership of the work.
BEG(UK)L to reconsider the degree of Human Factors expertise it requires, and how best to deliver that expertise.
BEG(UK)L to allow time in work plans for staff to be involved in research activities pertinent to their expertise and the company's interest.
BEG(UK)L and BEGL to develop the interface agreements between the Civil Design Group and other parts of the licensees to clarify the roles and responsibilities and to ensure that a clear specification of the work required reaches the Civils Group.
BEGL AND BEG(UK)L to clarify the arrangements to support the gas turbine standby supply capability on BEGL stations.
BEG(UK)L and BEGL to review the forward work load for the Electrical group, recognising the travel burden, to confirm additional personnel are not required.
BEG(UK)L to review the procedures for the specification, direction, and monitoring of work undertaken by satellite offices to ensure BEG(UK)L can demonstrate ownership of the product and understanding sufficient to allow appropriate safety related decisions to be made.
BEG(UK)L to provide in house expertise to cover the required SQEP posts within HSED and ensure safety significant issues are assessed in house.
BEG(UK)L to institute a system for review of the INSA process and to maintain an overview of the INSA process.
BEG(UK)L to review incidents at stations during the downsizing exercise to determine root causes and establish whether loss of corporate memory has been a factor.
BEG(UK)L to explain how it will ensure each Licensee is in control of its own procurement in the period after integration and before relicensing as a single Licensee.
BEG(UK)L to introduce measures to enhance collection and dissemination of contractor safety reports - both before and after computerisation.
BEG(UK)L to formalise the process by which the QA expertise is developed and maintained throughout the organisation.
BEGL and BEG(UK)L to complete a critical review of the working of the QA function across both Licensees to identify best practice and standards for adoption.
BEG(UK)L to review the data available to ensure an integrated view of an individual's experience is available as part of the SQEP review process.
BEG(UK)L to review the inputs into the additional hours worked figures to ensure they are representative of the whole of the Licensee.
BEGL and BEG(UK)L to define their state of readiness for integration and to demonstrate that adequate control of operations can be maintained throughout both Licensees (encompassing awareness of responsibilities, familiarity with procedures and work loads on staff).
BE to demonstrate how advice from a central technical team member of one Licensee to operating staff in the other Licensee will be reviewed by the intelligent customer of the operating Licensee.
BEGL to address the recommendations in this report by providing an action plan, to be completed within four weeks of receipt of this report, with proposals and timescales for resolving the recommendations.
BEG(UK)L to address the recommendations in this report by providing an action plan, to be completed within four weeks of receipt of this report, with proposals and timescales for resolving the recommendations.
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