Assessment of Proposal by Magnox Limited for Transition to a New

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Parent Body Organisation Competition for Magnox Limited and Research Sites Restoration Limited

Assessment of Proposal by Magnox Limited for Transition to a New Parent Body Organisation

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Office for Nuclear RegulationAn agency of HSE

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February 2014


Project Assessment Report: ONR-DFW-PAR-13-005Office for Nuclear Regulation An agency of HSE

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EXECUTIVE SUMMARY

Title

Assessment of proposal by Magnox Limited for transition to a new parent body organisation (PBO).

Permission Requested

In accordance with its nuclear site licence condition 36 arrangements, Magnox Limited has requested the agreement of the Office for Nuclear Regulation to ‘Management of Change Proposal MSO/01/2013 for the Magnox Limited Parent Body Organisation Competition Transition’ (8 August 2013).

Background

The Nuclear Decommissioning Authority (NDA) is currently running a competition for the parent body organisation (PBO) contracts for the site licence companies (SLCs) Magnox Limited (Magnox) and Research Sites Restoration Limited (RSRL). The PBO is the owner of the SLC, providing strategic vision, key personnel and expertise, but the SLC is the enduring entity responsible for safety. The preferred bidder for the new PBO will be announced in March 2014 with share transfer taking place on 1 September 2014.

Magnox has prepared a proposal for the management of the organisational changes associated with the transition to a new PBO. This covers the one-for-one replacement of up to 37 seconded PBO personnel, including the whole of the Executive team. There are no changes to organisational structures, staffing levels, responsibilities, management system arrangements or lifetime plans.

Magnox has categorised the change as ‘NB1’ (the highest category) and therefore, under its licence condition (LC) 36 compliance arrangements, is required to seek the agreement of the Office for Nuclear Regulation (ONR) before implementing the change.

Assessment and inspection work carried out by ONR in consideration of this request

My assessment considered the adequacy of Magnox’s arrangements for managing the transition to the new PBO from a safety perspective, including the arrangements for implementation, monitoring and review of the change.

Magnox’s management of change (MOC) proposal identifies the main risks to safety of the change as being a lack of competence of the incoming PBO, morale and safety culture impacts, increased workload and stress, and delays to work programmes.

My assessment tested the adequacy of Magnox’s risk assessment and the claims made in the MOC proposal to mitigate the identified risks. The specific topics I assessed (targeted at the key risks) were:

assurance of the competence of incoming PBO personnel;

knowledge transfer;

identification and management of organisational vulnerabilities;

impact on corporate emergency response capability;



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contingency planning for unexpected departure of the PBO; and

communications.

I informed my assessment through:

review of Magnox’s MOC proposal and supporting documentation;

meetings with the Magnox competition team to clarify the scope and nature of the proposed changes and mitigating action; and

interventions at three sites and in the central support functions to assess Magnox’s organisational resilience and the potential impacts of the change.

The main criteria I applied in my assessment was whether the mitigation measures proposed by Magnox would adequately control the risks to safety associated with the change. I used ONR’s Safety Assessment Principles (SAPs) and Technical Assessment Guides (TAGs) as the basis for my judgement.

ONR is not involved in decisions relating to the selection of the new PBO or nomination of individuals to PBO posts. These matters are therefore outside the scope of my assessment. I did however assess Magnox’s arrangements for assuring the competence of the incoming PBO personnel against LC 10 - Training and LC 12 - Duly authorised and other suitably qualified and experienced persons (SQEPs).

Matters arising from ONR’s work

I am satisfied that Magnox has adequately identified the risks associated with the transition to a new PBO. Following comments by ONR, the MOC proposal now assesses the potential for consequential loss of staff (beyond the PBO secondees), for example due to adverse safety culture impacts. Magnox identifies its processes for review and management of organisational vulnerabilities (see below) as the main risk control in this regard.

There is a lack of clarity in Magnox’s MOC proposal on the process it intends to follow for assuring the competence of incoming PBO personnel. After further clarification I was satisfied that the process to be adopted is objective and provides for the necessary degree of control by the SLC in accordance with its LC 10 and LC 12 compliance arrangements. The process developed by Magnox entails the establishment of a development review panel, comprising senior SLC staff and non-executive directors (non PBO), which will oversee the competence assurance process and make recommendations to the incoming Managing Director. Failure to meet competence requirements will be addressed through application of necessary restrictions and limitations, additional training and (ultimately) nomination of alternative personnel or implementation of the SLC’s contingency plan.

Although not detailed in its MOC proposal, I am satisfied - based on my interventions - that Magnox understands the requirement for, and will implement, a suitable process for transfer of knowledge from the outgoing PBO secondees to the incoming personnel. This recognises the need to identify and transfer tacit knowledge (inherent ‘know how’ and ways of working) using appropriate techniques.

Magnox has effective processes for identifying and managing its organisational vulnerabilities, eg singletons, demographic imbalance etc. These draw partly on its LC 36 compliance arrangements but also on generic processes for succession management and transition planning associated with implementation of the Magnox Optimised Decommissioning Programme (MODP). I considered that there was scope for improvement in the LC 36 compliance arrangements at Oldbury, Bradwell



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and in the Engineering Function (relating to vulnerability analysis and the scope of the nuclear baseline) which Magnox recognised and are actioning prior to share transfer.

Magnox has recognised the vulnerability in its corporate emergency response capability due to loss of the PBO personnel (most of the Central Emergency Support Centre (CESC) Controllers and safety advisers are PBO secondees). Magnox is mitigating this risk by training additional SLC personnel to fill these roles, and support the incoming PBO personnel, prior to 1 September 2014.

Magnox has reviewed and re-affirmed the adequacy of its contingency plan for wholesale exit of the PBO, recognising the increased risks during the competition period. The plan covers withdrawal of all PBO secondees and their replacement with SLC personnel.

Magnox has followed due process in its preparation of the MOC proposal for the PBO transition, including the categorisation of the change, risk assessment, identification of mitigating actions and review / endorsement. The MOC proposal and transition plan were subject to independent peer review. The MOC proposal was also reviewed at joint meetings of Magnox’s Nuclear Safety Committees (NSCs). Overall I consider the MOC proposal to have been subject to an appropriate level of independent challenge.

Magnox’s implementation of the PBO transition is being managed through workstreams (coordinated with the RSRL and NDA) and a transition plan, overseen by a dedicated board and its Nuclear Safety and Environment Council (NSEC). The arrangements for implementation of the change include readiness reviews before and during the transition phase (April - September 2014), monitoring of an enhanced set of key performance indicators and reviews of the change at defined times after share transfer. I sought clarification on the role of Magnox’s internal assurance function and was advised that its main focus will be on the processes for handover to, and competence assurance of, the incoming PBO personnel, which I consider appropriate.

Communications within Magnox on the PBO transition have been adequate to date and arrangements are in place for joint working between Magnox, RSRL and NDA on the future communications strategy.

Based on my interventions, I am satisfied that Magnox has taken into account lessons from previous PBO transitions for other SLCs. ONR was involved in these earlier transitions and the approach being applied by Magnox incorporates good practices that ONR has seen elsewhere.

I consulted the Environment Agency (EA), Natural Resources Wales (NRW) (Cyfoeth Naturiol Cymru) and the Scottish Environment Protection Agency (SEPA) on the project assessment report, who had no objection to its publication.

Conclusions

I conclude from my assessment that:

Magnox has adequately assessed the risks to safety of the transition to a new PBO; and

the risks of the change are adequately controlled, subject to satisfactory implementation by Magnox of the identified mitigating actions, as clarified through my assessment.

(The relevant clarifications, as detailed in the main body of my report, are:

- the process for assuring the competence of incoming PBO personnel;

- the process for knowledge transfer to incoming PBO personnel;



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- completion of actions to improve compliance with LC 36 at Oldbury, Bradwell and in the Engineering Function prior to share transfer; and

- the process of independent internal assurance and oversight of the PBO transition process.)

Magnox’s progress to date in implementing its transition plan gives me confidence that it is on track to complete the necessary mitigating actions prior to the change of PBO.

Recommendations

I recommend that:

ONR issues licence instruments to the Magnox Limited licensed sites, giving its agreement to Magnox to implement ‘Management of Change Proposal MSO/01/2013 for the Magnox Limited Parent Body Organisation Competition Transition’ (8 August 2013); and

ONR follows up during implementation of the change to check that the risks have been effectively mitigated (including follow-up on Magnox’s readiness reviews and post-implementation review of the change).



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LIST OF ABBREVIATIONS

CESC (Magnox) Central Emergency Support Centre

EA Environment Agency

EHSSQ Environment, Health, Safety, Security and Quality

HSE The Health and Safety Executive

IC Intelligent Customer

LC Licence Condition

MCP Management Control Procedure

MOC Management of Change

MODP Magnox Optimised Decommissioning Programme

NDA Nuclear Decommissioning Authority

NEBR National Emergency Briefing Room

NRW Natural Resources Wales (Cyfoeth Naturiol Cymru)

NSC Nuclear Safety Committee

NSEC (Magnox) Nuclear Safety and Environment Council

ONR Office for Nuclear Regulation (an agency of HSE)

PBO Parent Body Organisation

RSRL Research Sites Restoration Limited

SAP Safety Assessment Principle(s) (HSE)

SEPA Scottish Environment Protection Agency

SLC Site Licence Company

SQEP Suitably Qualified and Experienced Person

TAG (ONR) Technical Assessment Guide



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TABLE OF CONTENTS

1 ................................................................................................... 8 PERMISSION REQUESTED

2 ....................................................................................................................... 8 BACKGROUND

3 ................................................................................................................. 9

ASSESSMENT AND INSPECTION WORK CARRIED OUT BY ONR IN CONSIDERATION OF THIS REQUEST

3.1 ................................................................................................. 9 Objective of assessment

3.2 ...................................................................................................... 9 Scope of assessment

3.3 ........................................................................................ 10 Categorisation of the change

3.4 ........................................................................... 10 Impacts of the change and mitigation3.4.1 .......................................................................................... 10 Adequacy of risk assessment

3.4.2 ............................................ 12 Assurance of the competence of incoming PBO personnel

3.4.3 .......................................................................................................... 13 Knowledge transfer

3.4.4 ..................................... 13 Identification and management of organisational vulnerabilities

3.4.5 ...................................................... 15 Impact on corporate emergency response capability

3.4.6 .......................................... 16 Contingency planning for unexpected departure of the PBO

3.4.7 .............................................................................................................. 16 Communications

3.5 ................................................. 16 Implementation, monitoring and review of the change3.5.1 .......................................................... 16 Review and endorsement of the change proposal

3.5.2 ......................................................................................... 17 Implementation of the change

3.5.3 ............................................................................... 17 Monitoring and review of the change

4 ....................................................................................................... 18 LICENCE INSTRUMENT

5 .......................................................................... 18 MATTERS ARISING FROM ONR’S WORK

6 ..................................................................................................................... 21 CONCLUSIONS

7 .......................................................................................................... 21 RECOMMENDATIONS

8 ....................................................................................................................... 22 REFERENCES

Tables

Table 1: Posts covered by Magnox’s MOC proposal for the PBO transition



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1

2

PERMISSION REQUESTED

1 In accordance with its LC 36 arrangements, Magnox has requested the agreement of ONR to ‘Management of Change Proposal MSO/01/2013 for the Magnox Limited PBO Competition Transition’ (8 August 2013) (Ref 1).

BACKGROUND

2 NDA is currently running a competition for the PBO contracts for the Magnox and RSRL. The PBO is the owner of the SLC, providing strategic vision, key personnel and expertise, but the SLC is the enduring entity that holds the nuclear site licences and is responsible for safety. Currently there are separate PBOs for Magnox and RSRL but, following completion of the competition, there will be one PBO, although Magnox and RSRL will remain as separate licensees. The preferred bidder for the new PBO will be announced in March 2014 with share transfer taking place on 1 September 2014.

3 Magnox has prepared a proposal for the management of the organisational changes associated with the transition to a new PBO. The proposal comprises the following documentation:

Magnox NSC paper NP/SC/5197 (Revision 1, 27 August 2013);

MOC proforma MSO/01/2013 (8 August 2013); and

Competition Transition Plan, MX-COMP-009 (Issue 1.2, August 2013).

4 The proposal covers the one-for-one replacement of up to 37 seconded PBO personnel, comprising 31 nominated PBO posts and six ‘reachback’1 posts. The relevant posts include the whole Executive team, one of the four non-executive directors, the Engineering Director, the Chief Engineer (fuelled sites), five site directors (all non-fuelled sites) and four programme directors. The full list of posts is contained in NP/SC/5197 (Figures 1 and 2 - yellow shaded boxes) and summarised in Table 1 below. Excluded from the change scope are the Site Directors of Dungeness A, Chapelcross, Oldbury, Sizewell A and Wylfa, and the Programme Director - Fuel Element Debris. These are nominated PBO posts, but they are currently filled by SLC employees, who will remain in post. There are no changes to organisational structures, staffing levels, responsibilities, management system arrangements or lifetime plans.

5 Magnox has categorised the change as ‘NB1’ (the highest category2) under its LC 36 compliance arrangements (Ref 2), equivalent to ‘Major plus’ under the approved site-specific LC 36 arrangements for Oldbury and Wylfa (Refs 3 and 4). Under these arrangements Magnox is required to seek the agreement of ONR before implementing the change.

1 ie reach back into the PBO organisation for particular competences. 2 Proposals that if inadequately conceived or executed could have a ‘Major’ impact and have the potential to affect the validity of, or basis on which, the nuclear site licence was granted.



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3 ASSESSMENT AND INSPECTION WORK CARRIED OUT BY ONR IN CONSIDERATION OF THIS REQUEST

3.1 Objective of assessment

6 The objective of my assessment was to assess the adequacy of Magnox’s arrangements for managing the transition to the new PBO, in particular:

the adequacy of the risk assessment; and

whether the proposed mitigation measures will adequately control the risks to safety associated with the change.

3.2 Scope of assessment

7 The scope of my assessment covered:

the categorisation of the change (Section 3.3 below);

the impacts of the change and mitigation (Section 3.4); and

the implementation, monitoring and review of the change (Section 3.5).

8 In assessing the impacts of the change (2nd bullet) I focussed on the following topics, based on Magnox’s own assessment of the risks and intelligence gained from my interventions:

assurance of the competence of incoming PBO personnel;

knowledge transfer;

identification and management of organisational vulnerabilities;

impact on corporate emergency response capability;

contingency planning for unexpected departure of the PBO; and

communications.

9 My assessment of each of the above topics is covered in Section 3.4 below.

10 I informed my assessment through:

review of Magnox’s MOC proposal and supporting documentation (Ref 1);

meetings with the Magnox competition team to clarify the scope and nature of the proposed changes and mitigating action (Refs 5 and 6); and

interventions at three sites (Oldbury, Bradwell and Sizewell A) and in the central support functions (principally Engineering Function) to assess Magnox’s organisational resilience and the potential impacts of the change (Refs 6 - 9).

11 I used ONR’s Safety Assessment Principles and Technical Assessment Guides as the basis for my judgement, notably:

Safety Assessment Principles (SAPs) (Ref 10):

- MS.1 - Leadership

- MS.2 - Capable organisation

- MS.3 - Decision-making

- MS.4 - Learning from experience

Technical Assessment Guides (TAGs):



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- T/AST/027 - Training and Assuring Personnel Competence (Ref 11);

- NS-TAST-GD-048 - Organisational Capability (Ref 12);

- NS-TAST-GD-049 - Licensee Core and Intelligent Customer Capability (Ref 13); and

- NS-TAST-GD-065 - Function and Content of the Nuclear Baseline (Ref 14).

12 I also referred to relevant industry good practice, ie:

Safety Directors Forum ‘Nuclear Baseline and Management of Organisational Change’ (Ref 15).

13 The scope of my assessment relates specifically to the changes described in Magnox’s MOC proposal, as summarised in paragraph 4 above. Any further changes which the incoming PBO may wish to make after 1 September 2014 are outside the scope of this assessment and will be subject to due process under the Magnox’s LC 36 compliance arrangements. ONR is not involved in decisions relating to the selection of the preferred bidder or the nomination of individuals to the PBO posts, therefore these matters are also outside the scope of my assessment.

14 Conditions on management systems, appointment of SQEPs, and organisational structures and resources are included in the permits and authorisations granted by the respective environment agencies in England, Wales and Scotland. However, compliance with these permits and authorisations is administered separately by these agencies and is outside the scope of this assessment.

15 My assessment is timed in accordance with the NDA’s transition programme (ie ahead of announcement of the preferred bidder) and therefore precedes implementation of most of the mitigating actions identified in Magnox’s MOC proposal. The conclusions of my assessment are therefore predicated on effective implementation by Magnox of these actions although, through my interventions, I have been able to assess whether Magnox is on track in its implementation of the transition plan. Where appropriate I have sought further clarification on the nature and scope of Magnox’s mitigating actions and this is highlighted in Sections 3.3 - 3.5 and 6 below.

3.3 Categorisation of the change

16 Magnox conducted a screening assessment (NSC paper NP/SC/5197 - Appendix B) to inform its categorisation of the change associated with the PBO transition. This identifies two hazards which put the change in the high category (‘NB1’):

insufficient technical capability or poorly defined competence levels during, or as a result of, the change; and

inadequate emergency scheme capability.

17 The categorisation of the change as ‘NB1’ is in accordance with ONR’s expectations (NS-TAST-GD-048, Appendix 3) and reflects the risk associated with loss of up to 37 senior personnel with considerable collective knowledge and experience. It is therefore appropriate that the MOC proposal it is subject to the highest level of scrutiny within Magnox and formal agreement by ONR.

3.4 Impacts of the change and mitigation

3.4.1 Adequacy of risk assessment

18 Magnox’s MOC proposal identifies ten broad safety hazards associated with the PBO transition, of which the more significant (category ‘NB1’ and ‘NB2’) are:



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insufficient resources or organisation resilience during, or as a result of, the change;

unclear responsibilities during or as a result of the change;

insufficient technical capability or poorly defined competence levels during, or as a result of, the change;

adverse work related stress during, or as a result of, the change;

inadequate emergency scheme capability; and

potential impacts on morale of staff, particularly incumbent PBO staff.

19 Magnox’s updated MOC proposal addresses earlier ONR comments and includes an assessment of the risk of loss of other staff (in addition to the PBO secondees), particularly singletons on post retirement or zero hours contracts (Section 4.11 of the MOC proposal). Magnox’s reliance here is on its processes to review and manage organisational vulnerabilities, which I have assessed in Section 3.4.4 below.

20 Magnox’s risk assessment for the PBO transition was informed by its participation in a Hazard and Operability (HAZOP) study by RSRL (Ref 24). The HAZOP was chaired by someone independent of the competition process and included the competition project managers and MOC co-ordinators from both SLCs. The HAZOP followed a structured approach to identify affected stakeholders, hazards and their causes, potential consequences, controls and mitigation, and recommendations / monitoring action.

21 I sought to confirm the adequacy of Magnox’s risk assessment through my interventions at sites and in the central functions. This indicated that the direct impacts of the PBO transition at the site or ‘working’ level are expected to be minimal based on experience of similar previous transitions (eg Magnox South and Magnox North merger) and in the context of the transitions already underway related to defuelling and decommissioning. I was also informed during these interventions that the three reachback personnel at the Oldbury and Bradwell sites (see Table 1) have already been replaced and therefore no longer represent a risk for the PBO transition.

22 My interventions confirmed the following risks (already identified by Magnox):

impact on staff morale due to uncertainty as to the new PBO’s intentions. Magnox’s reliance here is on good communications, which I have assessed in Section 3.4.7.

impact on work programmes (particularly those that are due to start over the coming period) due to loss of key PBO personnel in the Strategic Projects function. Based on discussions with Magnox, its reliance here is on effective processes for competence assurance, training and handover to incoming personnel during the transition period - see Sections 3.4.2 and 3.4.3 - not only on programme performance monitoring, as stated in NSC paper NP/SC/5197. Historically the PBO posts in Strategic Projects were reachback posts but were changed to nominated posts to facilitate pro-active handover to a new PBO (ie requirement for incoming PBO to nominate replacements and follow a formal handover process).

23 I was satisfied with Magnox’s general awareness of the indirect impacts of the transition, ie the support required for training and handover activities, shadow working and due diligence during the transition period. In this regard Magnox has directed staff to complete financial year-end activities, eg performance appraisals, early where possible to minimise the impact on the start of the PBO transition period.

24 Magnox’s risk assessment identifies mitigating actions which either reflect established management processes and procedures or are detailed in the transition plan.



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3.4.2 Assurance of the competence of incoming PBO personnel

25 There is a lack of clarity in Magnox’s MOC proposal on the process it intends to follow to assure the competence of the incoming PBO personnel. For example the transition plan (Section 11.1) refers to the SQEP assessment of new appointees as being ‘a matter for the incoming PBO’, whereas the NSC paper (Section 4.14) states that ‘the non-executive members of the Magnox Limited Board will also consider, and form a view on, the competence, capability and suitability of the senior incoming PBO secondees and advise the Managing Director accordingly’.

26 Based on previous PBO competitions, and in accordance with its TAGs, ONR’s expectations are that the process for assuring the competence of new PBO appointees should be objective and provide for the necessary degree of control by the SLC in accordance with its LC 10 and LC 12 compliance arrangements.

27 I carried out further interventions to clarify the competence assurance process Magnox intends to follow, which is set out in Ref 16. The process provides for the establishment of a development review panel comprising senior SLC staff and non-executive directors (non-PBO persons) to oversee the competence assurance process, which will be carried out in accordance with Magnox’s MCP-10 (Learning and Development) (Ref 17) and MCP-10-01 (Management of Competence and SQEP capability) (Ref 18) procedures. The main steps are as follows:

Competition phase (until March 2014):

- interview of incumbent PBO personnel to confirm role profiles and identify SQEP requirements, tacit knowledge and experience.

- preparation of handover packs for each PBO post including quality plans for training, authorisations and appointments, formal briefs, knowledge transfer activities and directed reading.

After announcement of preferred bidder (31 March 2014):

- gap analysis of incoming PBO competences against handover packs (learning schedule amended as appropriate).

- completion of learning by the individuals concerned.

- independent review of individual assessments and overall assessment of collective capability at business level.

- SLC SQEP panel assessment of prospective post-holders and recommendation to incoming Managing Director.

- meeting between SLC SQEP panel chair, new Managing Director and each prospective post-holder to confirm common understanding and agreement of recommendations.

28 At share transfer (1 September 2014):

- Managing Director and post-holder sign-off of competence assessment form including confirmation of any restrictions or limitations.

29 Failure to meet competence requirements will be addressed through application of necessary restrictions and limitations, additional training and (ultimately) nomination of alternative personnel or implementation of the SLC’s contingency plan (see Section 3.4.6 below).



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30 Magnox’s arrangements do not cover assessment of the behavioural competence of the incoming PBO personnel. However NDA has tested the safety culture approaches of the bidders at both the pre-qualification and tender stages of the competition. Also NDA has asked the bidders to describe the selection processes that they propose to utilise for nominated staff, including addressing behavioural competence, which will form part of the bidder evaluation.

31 Overall I was satisfied that the process Magnox intends to follow to assure the competence of incoming PBO personnel meets ONR’s expectations. Magnox has so far completed the interviews of incumbent PBO personnel (first step as above) which it is using to inform preparation of the handover packs.

3.4.3 Knowledge transfer

32 Magnox recognises the potential for loss of considerable knowledge from its business as a result of the departure of the incumbent PBO personnel. The competence profile of the incoming personnel will not be known until after the announcement of the preferred bidder so Magnox is planning on the basis that they could be foreign nationals with limited prior knowledge of the UK regulatory context and no prior knowledge of Magnox and its sites (‘maximum change case’ - see Section 4.2 of NSC paper).

33 Magnox has recognised the need for a systematic process to transfer knowledge from the existing PBO personnel to their successors, in particular to identify and transfer the tacit knowledge of the incumbents (inherent ‘know how’ and ways of working). As part of my interventions I sought further detail on how and when this was to be done (Ref 6).

34 Magnox has outlined processes for knowledge transfer which cover both peer-to-peer interactions between the incumbent PBO and preferred bidder and between the PBO and SLC. The latter is appropriate given the depth to which the PBO holds nominated positions within the SLC and also recognising that the new PBO will be joining part way through the financial year, therefore will not be exposed to the full cycle of the SLC’s activities.

35 Magnox is proposing suitable methods to identify and transfer tacit knowledge which include:

structured peer-to-peer discussions (with internal facilitator and specialist external facilitator provided via an NDA framework contract);

network mapping (to identify the knowledge ‘gatekeepers’ within the SLC);

concept mapping (to identify how to get things done); and

‘pearls of wisdom’ (to identify priority activities, meetings, contacts etc).

36 Magnox has initially scheduled the peer-to-peer discussions for the early part of the transition period (May 2014), based on learning from the Dounreay PBO transition, and estimates 20 sessions over a two week period.

37 Overall, based on the above, I am satisfied that Magnox is adopting a suitably systematic approach to knowledge transfer which recognises the need to identify and transfer the tacit knowledge of the incumbent PBO personnel.

3.4.4 Identification and management of organisational vulnerabilities

38 Through my interventions at Oldbury, Bradwell and Sizewell A, and in the Engineering Function, I assessed the effectiveness of Magnox’s processes for identifying and managing its organisational vulnerabilities. I considered Magnox’s implementation of its LC 36 compliance arrangements but also its generic processes for succession



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management (S-178) (Ref 19) and transition planning as part of implementation of the MODP.

39 I was satisfied that Magnox could demonstrate an adequate understanding of its organisational vulnerabilities and that action has been (or will be) taken to address these vulnerabilities. The reliance was primarily on generic succession management and transition planning rather than LC 36 compliance arrangements and, in respect of the latter, I identified opportunities for improvement, which Magnox is addressing prior to PBO share transfer.

40 Specifically at the sites and central functions I visited I observed the following:

41 Oldbury (Ref 7). I sampled succession management in the engineering team at Oldbury and found evidence of regular reviews which identified a range of vulnerabilities, eg singletons and impending retirement, and necessary mitigating action. The scope of this work included technical specialists overseeing nuclear safety related contract work at the site. I also sampled the ‘Your Future Choices’ workforce planning process associated with the site’s transition to fuel-free status in 2015. As above this identified a range of vulnerabilities across the site (reviewed at lead team level) and necessary mitigating action. Oldbury’s LC 36 compliance arrangements (Ref 3) are site-specific and do not include the requirement for an annual resilience review (as per MCP-36) which would improve the linkage between the succession / transition planning and the nuclear baseline, and provide for greater visibility of vulnerabilities. Oldbury has taken action to adopt MCP-36 as its LC 36 compliance basis.

42 Bradwell (Ref 8). At Bradwell it was apparent that there are risks to the site’s organisational resilience (eg erosion of defence in depth and longer working hours) but that action has been taken to mitigate these risks (eg procurement of additional resource and enhanced monitoring of excess hours). I considered that the site’s processes for managing its transition into care and maintenance (Closure Programme Governance Board and personal pathway planning) were adequate but that there was scope for improvement in the nuclear baseline justification and annual resilience review. The latter did not appear to consider all posts and did not clearly identify technical singleton dependence. Bradwell recognised these improvement opportunities and will be issuing an MOC proposal to re-validate its nuclear baseline.

43 Sizewell A (Ref 9). As at Oldbury I considered the processes at Sizewell A to manage the transition to fuel-free status in 2014, based on aspirational counselling and ‘best fit’ analysis, to be sound. I also found evidence of effective succession planning processes within functions and at site level. The site’s resilience review drew largely on the output of the quarterly review of succession plans rather than providing a separate analysis. Resourcing issues identified in the sites annual EHSSQ review had been addressed.

44 Engineering Function (Ref 6). The Engineering Function manages its organisational vulnerabilities principally through annual reviews of intelligent customer (IC) capability (Refs 20 and 21). This covers approximately half the posts within the Engineering Function. I found these reviews to address a range of vulnerabilities, in particular singleton dependence and impending retirement, linked to the company’s requirement to support ongoing generation, defuelling and decommissioning activity across the portfolio. It is apparent from these reviews that there is significant dependence on singletons, eg there are 27 singleton sub-skills in respect of short term support requirements and, over the medium term (3 years), nine IC topics (out of 50) where there is an ‘amber’ risk3 and

3 Medium risk of insufficient IC skill, succession plan required.



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one where there is a ‘red’ risk4. In assessing the acceptability of this situation Magnox considers the likely demand for the IC skill, the circumstances of the individuals concerned and the contingency support available either through training other staff or from EDF Energy (in respect of ongoing Wylfa generation). Magnox has identified necessary further mitigating actions and I found that all the short term actions (to March 2013) and 5 of the 20 medium term actions (to March 2014) had been closed as at 21 August 2013 (Ref 22). The two Chief Engineers (fuelled / non-fuelled sites) confirmed that the ultimate potential consequences of loss of singleton expertise (ie cessation of generation at Wylfa) were understood within Magnox. This supports the commitment in the MOC proposal to application of operational decision-making processes in situations of acute loss of skills which may ultimately restrict or delay operations and programmes.

45 The MOC proposal for the PBO transition identifies two IC skills where, as a result of loss of PBO secondees, there is a need to strengthen in-house capability. In both these areas Magnox considers that it can develop the necessary additional SQEP.

46 The Engineering Function recognised that its current nuclear baseline definition is insufficient in that it only covers the first three levels of the organisation (17 posts), whereas there are others carrying out nuclear safety related work who are not covered by the definition of IC (above) and therefore not included in periodic reviews of vulnerability as per MCP-36. As a result of my intervention, Magnox agreed to ensure full implementation of MCP-36 in its Engineering Function by June 2014.

47 Overview. As noted above I was content overall that Magnox could demonstrate an adequate understanding of its organisational vulnerabilities and that action has been (or will be) taken to address these vulnerabilities. I was satisfied that the issues I identified in my interventions (above) would not prevent ONR’s agreement to the MOC proposal for the PBO transition. My recommendation (see Section 7 below) to carry out further interventions during the course of the PBO transition provides the opportunity for ONR to examine generically (across all sites) Magnox’s LC36 compliance arrangements.

3.4.5 Impact on corporate emergency response capability

48 Magnox has recognised the vulnerability in its corporate emergency response capability due to loss of the PBO personnel. PBO secondees currently account for six of the seven appointed Central Emergency Support Centre (CESC) Controllers, all of the National Emergency Briefing Room (NEBR) responders and two of the three appointed safety advisers. The minimum required numbers are three in each case.

49 In mitigation of the above, Magnox is requiring the incoming PBO to nominate six new CESC Controllers who will undertake necessary training and familiarisation (including assessment via desktop emergency exercises) to enable them to fulfil their roles by the time of share transfer. Magnox however recognises that this will still leave a vulnerability in its arrangements in terms of the senior emergency response team’s experience, particularly to attend the NEBR. Magnox is therefore also training two additional SLC staff to act as CESC Controllers and has added the role of NEBR attendance to the duties of its Assistant CESC Controllers, nine out of ten of whom are SLC staff. Magnox is also training three EHSSQ site inspectors to act as safety advisers and is also developing one new Assistant CESC Controller. I clarified that the new CESC Controllers and Assistant Controller are not currently part of the emergency scheme so represent extra resource to support an extended emergency.

4 High risk of insufficient IC skill, action required.



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50 A specialist from ONR’s Emergency Preparedness and Response team reviewed Magnox’s proposed mitigation and was satisfied that, at this stage, the mitigation is adequate. However the specialist suggested following up to ensure that Magnox remains capable of delivering a competent response to an extended emergency. My recommendation to follow-up generally on the implementation of the PBO transition (see Section 7 below) provides the opportunity to do this.

3.4.6 Contingency planning for unexpected departure of the PBO

51 Magnox advised me that its Managing Director has reviewed and re-affirmed the adequacy of its contingency plan for wholesale exit of the PBO. I consider it appropriate that the SLC has done this given the increased risks during the competition period. The plan covers withdrawal of all PBO secondees (which in any case would be in default of the PBO’s agreement with NDA) and their replacement with SLC personnel, appointed by the non-executive directors. I note also that the NDA has put in place arrangements to incentivise the incumbent PBO to deliver the transition.

3.4.7 Communications

52 During my interventions at the sites and in the central functions I reviewed the communications within Magnox to date on the PBO transition. I also asked about the plan for communications throughout the remainder of the competition period, given the reliance on effective communications as a mitigation measure against unsettling SLC staff.

53 There have been good communications to date on the PBO transition from both the SLC and NDA covering site lead teams, staff, site stakeholder groups and trades unions. These have been delivered both verbally and in writing, with the opportunity for those concerned to raise questions.

54 Communication forms one of the joint SLC-NDA workstreams for implementation of the PBO transition and there have been several meetings to date including the opportunity to learn lessons from the recent Dounreay PBO transition. The intent of the SLCs and NDA is to develop a joint communications strategy which I consider appropriate given that there is one incoming PBO.

55 In its communications planning, Magnox is emphasising that the incumbent PBO personnel remain in control up to the point of share transfer, which I support. NDA is also attaching importance to early communications by the preferred bidder to the workforces of both Magnox and RSRL across the 12 affected sites. As at the date of my assessment, NDA had prepared draft communications materials for the preferred bidder announcement.

3.5 Implementation, monitoring and review of the change

3.5.1 Review and endorsement of the change proposal

56 I am satisfied that Magnox has followed due process in its preparation of the MOC proposal for the PBO transition, including the categorisation of the change, risk assessment, identification of mitigating actions and review / endorsement. The MOC proposal was subject to independent internal review and the transition plan was subject to independent external review jointly with RSRL’s transition plan (Ref 23). The MOC proposal was also reviewed at joint meetings of Magnox’s NSCs in July 2013 and again in August 2013. Overall I consider the MOC proposal to have been subject to an appropriate level of independent challenge. The MOC proposal is endorsed for issue by the EHSSQ Director, a Board member.



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3.5.2 Implementation of the change

57 Magnox’s implementation of the PBO transition is being managed through workstreams (coordinated with the RSRL and NDA) and a transition plan, overseen by a dedicated board (the Magnox Competition Programme Board) and its NSEC. The joint SLC-NDA workstreams are yet to be fully defined but will cover:

process governance;

assurance and review;

SQEP organisation;

EHSSQ;

business ownership transfer;

logistics;

communications and stakeholder engagement; and

due diligence

58 Magnox’s transition plan incorporates the mitigating actions identified in the MOC proposal and covers the competition, transition and consolidation phases of the PBO change. Each bidder must develop a transition plan and it is a requirement of NDA that the preferred bidder’s plan docks with that of the SLC.

59 The Magnox Competition Programme Board is chaired by the Managing Director and comprises four other directors together with the Programme Integrator. Its terms of reference charge it to oversee the development and implementation of the transition plan, ensuring that the necessary resources are available to deliver the overall objective of transfer of PBO secondees at share transfer in the best interest of the SLC. A key aspect is ensuring that neither the competition nor transition adversely affect the safety and security of the company. The Competition Programme Board meets at least quarterly and is accountable (through its Chair) to the main Magnox Board. Overall I am satisfied that there is sufficient leadership oversight within Magnox of the transition process. Outside Magnox the tripartite meeting of NDA, SLCs, regulators and (in due course) the preferred bidder will continue and a senior review group, comprising senior representatives of each organisation, will meet for the first time in early 2014 to oversee the process.

60 Magnox’s MOC proposal expresses the desirability of a period of stability either side of share transfer. Up to the point of share transfer Magnox is proposing to provide a stable structure with no organisational change other than normal operational changes at function and site levels. As regards the period after share transfer, NDA has stated that all bidders have accepted the principle of a period of stability. Any further proposed changes will have to follow the SLC’s due process. NDA has set a nine month consolidation period after share transfer during which it requires the PBO to move to its new lifetime plan and implement any necessary organisational change.

3.5.3 Monitoring and review of the change

61 In its MOC proposal, Magnox has set out an enhanced set of key performance indicators that it will use to monitor impact of the transition to the new PBO. This comprises an enhanced set of organisational resilience indicators (eg new PBO personnel not meeting SQEP requirements, rate of staff leaving the business, compliance transgressions, audit findings etc) together with outputs from the readiness reviews - see below. In accordance with its MOC proposal, Magnox also completed a stress (wellbeing) survey in



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September 2013 and safety culture survey in November 2013. The latter will be repeated post change on a selective basis.

62 In coordination with RSRL, Magnox’s transition plan provides for five readiness reviews to be conducted at key points during the competition and transition phases. The purpose of these is to test (through self-assessment) Magnox’s compliance with the MOC proposal and transition plan and hence its readiness for the next phase of transition, in particular preferred bidder announcement and share transfer. The reviews will cover such aspects as delivery of training and handover, emergency scheme capability and communications plan deployment (see NSC paper NP/SC/5197 - Summary of key performance indicators to be monitored).

63 Magnox’s Head of Assurance will verify the readiness reviews to ensure that the transition is being carried out in accordance with the MOC proposal and transition plan. I sought further clarification on the role of the internal assurance function (Ref 6) and was advised that it had yet to finalise the scope of its activities, but that its main focus will be on the process for handover to, and assurance of the competence of, the incoming PBO personnel. It is planned that this will be done via three insertion points to test (i) availability of adequate training and familiarisation material, (ii) adequacy of gap analysis of each incoming PBO person and (iii) completion of handover and training activities, including totality of SQEP limitations. I consider this approach satisfactory.

64 Magnox’s MOC proposal commits to post-implementation review of the PBO transition at one, three, six and 12 months after share transfer.

LICENCE INSTRUMENT

65 This project assessment report supports ONR’s decision on whether or not to agree to Magnox’s request, under its LC 36 compliance arrangements, to implement ‘Management of Change Proposal MSO/01/2013 for the Magnox Limited Parent Body Organisation Competition Transition’ (8 August 2013). This will be done via issue of a licence instrument under ONR’s internal instructions (Ref 25). On the advice of the Superintending Inspectors, the format I have followed for the licence instrument is ‘H1’ in Appendix 3 of Ref 25 (routine licence instruments). I have not therefore consulted the Treasury Solicitor’s Office (as would be required for non-routine licence instruments). H1 is the same format as used for the Dounreay PBO transition licence instrument (LI 513, unique no. DNE71840, 8 November 2011).

MATTERS ARISING FROM ONR’S WORK

66 I am satisfied that Magnox has adequately identified the risks associated with the transition to a new PBO. Following comments by ONR, the MOC proposal now assesses the potential for consequential loss of staff (beyond the PBO secondees), for example due to adverse safety culture impacts. Magnox identifies its processes for review and management of organisational vulnerabilities (see below) as the main risk control in this regard.

67 There is a lack of clarity in Magnox’s MOC proposal on the process it intends to follow for assuring the competence of incoming PBO personnel. After further clarification I was satisfied that the process to be adopted is objective and provides for the necessary degree of control by the SLC in accordance with its LC 10 and LC 12 compliance arrangements. The process developed by Magnox entails the establishment of a SQEP review panel, comprising senior SLC staff and non-executive directors (non PBO), which



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will oversee the competence assurance process and make recommendations to the incoming Managing Director. Failure to meet competence requirements will be addressed through application of necessary restrictions and limitations, additional training and (ultimately) nomination of alternative personnel or implementation of the SLC’s contingency plan.

68 Although not detailed in its MOC proposal, I am satisfied - based on my interventions - that Magnox understands the requirement for, and will implement, a suitable process for transfer of knowledge from the outgoing PBO secondees to the incoming personnel. This recognises the need to identify and transfer tacit knowledge (inherent ‘know how’ and ways of working) using appropriate techniques.

69 Magnox has effective processes for identifying and managing its organisational vulnerabilities, eg singletons, demographic imbalance etc. These draw partly on its LC 36 compliance arrangements but also on generic processes for succession management and transition planning associated with implementation of the MODP. I considered that there was scope for improvement in the LC 36 compliance arrangements at Oldbury, Bradwell and in the Engineering Function (relating to vulnerability analysis and the scope of the nuclear baseline) which Magnox recognised and are actioning prior to share transfer.

70 Magnox has recognised the vulnerability in its corporate emergency response capability due to loss of the PBO personnel (most of the CESC Controllers and safety advisers are PBO secondees). Magnox is mitigating this risk by training additional SLC personnel to fill these roles, and support the incoming PBO personnel, prior to 1 September 2014.

71 Magnox has reviewed and re-affirmed the adequacy of its contingency plan for wholesale exit of the PBO, recognising the increased risks during the competition period. The plan covers withdrawal of all PBO secondees and their replacement with SLC personnel.

72 Magnox has followed due process in its preparation of the MOC proposal for the PBO transition, including the categorisation of the change, risk assessment, identification of mitigating actions and review / endorsement. The MOC proposal and transition plan were subject to independent peer review. The MOC proposal was also reviewed at joint meetings of Magnox’s NSCs. Overall I consider the MOC proposal to have been subject to an appropriate level of independent challenge.

73 Magnox’s implementation of the PBO transition is being managed through workstreams (coordinated with the RSRL and NDA) and a transition plan, overseen by a dedicated board and its NSEC. The arrangements for implementation of the change include readiness reviews before and during the transition phase (April - September 2014), monitoring of an enhanced set of key performance indicators and reviews of the change at defined times after share transfer. I sought clarification on the role of Magnox’s internal assurance function and was advised that its main focus will be on the processes for handover to, and competence assurance of, the incoming PBO personnel, which I consider appropriate.

74 Communications within Magnox on the PBO transition have been adequate to date and arrangements are in place for joint working between Magnox, RSRL and NDA on the future communications strategy.

75 Based on my interventions, I am satisfied that Magnox has taken into account lessons from previous PBO transitions for other SLCs. ONR was involved in these earlier transitions and the approach being applied by Magnox incorporates good practices that ONR has seen elsewhere.



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76 I consulted the EA, NRW and SEPA on the project assessment report, who had no objection to its publication.



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CONCLUSIONS

77 I conclude from my assessment that:

Magnox has adequately assessed the risks to safety of the transition to a new PBO; and

the risks of the change are adequately controlled, subject to satisfactory implementation by Magnox of the identified mitigating actions, as clarified through my assessment.

(The relevant clarifications are:

- the process for assuring the competence of incoming PBO personnel, as per Section 3.4.2 above and Ref 16;

- the process for knowledge transfer to incoming PBO personnel, as per Section 3.4.3 and Ref 6;

- completion of actions to improve compliance with LC 36 at Oldbury, Bradwell and in the Engineering Function, as per Section 3.4.4 and Refs 6 - 8, prior to share transfer; and

- the process of independent internal assurance and oversight of the PBO transition process, as per Sections 3.5.2 and 3.5.3, and Ref 6).

78 Magnox’s progress to date in implementing its transition plan gives me confidence that it is on track to complete the necessary mitigating actions prior to the change of PBO.

RECOMMENDATIONS

79 I recommend that:

ONR issues Licence Instruments to the Magnox Limited licensed sites, giving its agreement to Magnox for implementing ‘Management of Change Proposal MSO/01/2013 for the Magnox Limited Parent Body Organisation Competition Transition’ (8 August 2013); and

ONR follows up during implementation of the change to check that the risks have been effectively mitigated (including follow-up on Magnox’s readiness reviews and post-implementation review of the change).



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8 REFERENCES

1 Letter from K Spooner (Magnox Limited) to R Campbell (ONR) requesting agreement to the management of change proposal MSO/01/2013 for the Magnox Limited PBO competition transition, 17 December 2013, Ref MXL32168/Y, with attachments as follows: Nuclear Safety Committee paper NP/SC/5197, Revision 1 (27 August 2013); Management of Change proforma MSO/01/2013 (8 August 2013); Transition plan MX-COMP-009, Issue 1.2 (August 2013); Minutes of joint meeting of ten Nuclear Safety Committees on 16 August 2013

considering paper NP/SC/5197; Advanced copy of Nuclear Safety Committee paper NP/SC/5197 (June 2013); Advanced copy of Management of Change proforma MSO/01/2013; Transition plan MX-COMP-009, Issue 1 (June 2013); Minutes of joint meeting of fuelled sites Nuclear Safety Committees on 9 July 2013

considering advanced copies of NP/SC/5197 and MSO/01/2013; and Minutes of joint meeting of defuelled sites Nuclear Safety Committees on 10 July

2013 considering advanced copies of NP/SC/5197 and MSO/01/2013. (See TRIM 2013/472497 and 2014/016668)

2 Management of Organisational Change, MCP-36, Issue 2, August 2012 (TRIM 2014/016686).

3 Oldbury Site Management Control Procedure - Management of Change, OLD/MCP/01/002, Issue 15, January 2012 (TRIM 2014/016702).

4 Arrangements for Compliance with Site Licence Condition 36 at Wylfa Power Station, WYA/MOC, Issue 1, August 2000 (TRIM 2014/016716).

5 ONR-DFW-CR-13-179, Update on Magnox Limited’s Preparations for the PBO Transition (Level 4), 17 October 2013 (TRIM 2013/412631).

6 ONR-DFW-CR-13-199, Update on Magnox Limited’s Preparations for the PBO Transition (Level 4), 29 November 2013 (TRIM 2013/474010)

7 ONR-OLD-IR-13-007, Oldbury power station - intervention to assess the site’s organisational resilience and capability ahead of Magnox Limited’s transition to a new parent body organisation in 2014, 14-15 October 2013 (TRIM 2013/405366).

8 ONR-BWA-IR-13-004, Bradwell power station - intervention to assess the site’s organisational resilience and capability ahead of Magnox Limited’s transition to a new parent body organisation in 2014, 5-6 November 2013 (TRIM 2013/437069).

9 ONR-SZA-IR-13-004, Sizewell A power station - intervention to assess the site’s organisational resilience and capability ahead of Magnox Limited’s transition to a new parent body organisation in 2014, 3-4 December 2013 (TRIM 2014/003517)

10 Safety Assessment Principles for Nuclear Facilities. 2006 Edition Revision 1. HSE. January 2008. www.hse.gov.uk/nuclear/SAP/SAP2006.pdf.

11 ONR Technical Assessment Guide - Training and Assuring Personnel Competence, T/AST/027, Issue 3, September 2010. http://www.hse.gov.uk/nuclear/operational/tech_asst_guides/index.htm

12 ONR Technical Assessment Guide - Organisational Capability, NS-TAST-GD-048, Revision 4, March 2013. http://www.hse.gov.uk/nuclear/operational/tech_asst_guides/index.htm

13 ONR Technical Assessment Guide - Licensee Core and Intelligent Customer Capability, NS-TAST-GD-049, Revision 4, April 2013. http://www.hse.gov.uk/nuclear/operational/tech_asst_guides/index.htm



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14 ONR Technical Assessment Guide - Function and Content of the Nuclear Baseline, NS-TAST-GD-065, Revision 2, May 2013. http://www.hse.gov.uk/nuclear/operational/tech_asst_guides/index.htm

15 Nuclear Baseline and the Management of Organisational Change, A Nuclear Industry Code of Practice, First Edition, October 2010.

16 Magnox Limited PBO Transition Arrangements - Process for Achieving SQEP Status, MX-COMP-010 (TRIM 2014/003910).

17 Magnox Company Management of Control Procedure MCP-10 - Learning and Development, Issue 3, September 2013 (TRIM 2014/016730).

18 Magnox Company Management of Control Procedure MCP-10-01 - Management of Competency and SQEP Capability, Issue 4, April 2013 (TRIM 2014/016737).

19 Magnox Company Standard S-178 - Performance Management and Development Governance Arrangements, Issue 4, May 2013 (TRIM 2014/016752).

20 Magnox Intelligent Customer Assurance Report, M/EF/GEN/REP/0007/13, Issue 1, June 2013.

21 Magnox Engineering Function - Identification of Potential Appointed IC Shortfall in MagnoxLimited in the Light of Extended Generation at Wylfa, November 2012.

22 Magnox IC Skill Gap Closure Actions, Status on 21 August 2013.

23 An Independent Review of the Plans being made by RSRL and Magnox Limited to Transition their Site Licence Companies to a new PBO, B Jones and M Potts, June 2013 (TRIM 2013/350097).

24 RSRL/MoCComp/HAZOP/001 HAZOP Report for Transition to a New Parent Body Organisation (PBO) Following Magnox/RSRL PBO Competition, Issue 2, August 2013 (TRIM 2013/350097).

25 Preparation and Issue of Licence Instruments, NS-PER-IN-001, Revision 4, May 2013.


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Table 1

Posts covered by Magnox’s MOC proposal for the PBO transition

No. Post title

Nominated PBO posts

1 Non-Executive Director

2 Managing Director

3 Transformation Director

4 Communications Director

5 Strategic Programmes Director

6, 7 Chief Operating Officers (2)

8 Chief Nuclear Officer

9 Engineering Director

10 EHSSQ Director

11 Business Director

12 Commercial Director

13 HR Director

14 -18 Site Directors - Berkeley / Bradwell / Hinkley Point A / Hunterston A / Trawsfynydd (5)

19 Care and Maintenance Hub Director

20 - 23 Programme Directors - Ponds / Intermediate Level Waste / Plant and Structures / Waste (4)

24 Programme Delivery Manager - Intermediate Level Waste

25 Project Manager - Waste Programme

26 Project Engineer - Waste Programme

27 Head of Finance

28 Head of Baseline and Performance Delivery

29 Head of Customer Contracts

30 Employee Relations Manager

31 Workforce Transition Manager

Reachback PBO posts

1 Baseline Integrity Manager

2 Chief Engineer Fuelled Sites

3 Waste Manager (Bradwell)

4 Project Manager (Bradwell)

5 Stakeholder Engagement (Care and Maintenance)

6 EHSSQ Manager (Oldbury)

Documents

Assessment of Proposal by Magnox Limited for Transition to a New