ONR decided to undertake this reactive, unplanned intervention because it wished to establish the sequence of decisions, and their rationale, that led to the final decision taken by NNB GenCo on 23rd March to proceed with the placement of FNSC while there remained outstanding NCRs relating to the condition of the underlying formation level and sub-structure. Such a decision was viewed by ONR to be unexpected, particularly in the light of assurances given by NNB GenCo to ONR the previous week that FNSC would not proceed until the NCRs were resolved.
ONR's site visits and meetings with NNB GenCo in relation to this intervention were:
The intervention found that NNB GenCo failed to fully match ONR's expectations on leadership & decision making. The noted deficiencies related to:
Individual deficiencies, taken on their own, may not be of such seriousness as to raise regulatory concern; in aggregation, however, they indicate a broader shortfall in NNB GenCo's systems and processes. Given the efforts NNB GenCo has made, and is undertaking to foster an appropriate project culture and arrangements, this is disappointing. However ONR acknowledges that the arrangements are in the early phase of being stressed and refined, and NNB GenCo itself had recognised the situation and instigated an investigation. NNB GenCo should take this opportunity to look at the lessons that can be learned from these events and strengthen its arrangements.
ONR's consideration of the events and issues that emerged during the excavation for technical gallery and subsequent decision to proceed with FNSC provided the opportunity to observe how NNB GenCo implemented its arrangements for compliance with Licence Conditions 6, 17, 19 and 20. ONR's findings in relation to these LCs was that NNB GenCo's compliance was generally unsatisfactory. Apart from LC6 (where ONR had concerns about the adequacy of record keeping, but had insufficient evidence to come to a firm judgment), the other three LCs were judged by ONR to be either below standard or significantly below standard. These are rated as 'Amber' according to ONR's red-amber-green inspection rating scheme. Amber ratings require ONR to raise Regulatory Issues where relevant and seek appropriate improvements from the licensee. The licensee will be expected to develop an improvement plan which sets out its intended actions to return the inspection ratings to 'Green' and to address any other shortfalls identified through this intervention.
ONR's consideration of the events discussed in this IR has identified several deficiencies in internal communications within NNB GenCo and its partner organisations. The events have also raised concerns over the openness, consistency and timeliness of NNB GenCo's communications with ONR, which had previously been excellent. This has the potential to undermine progress towards the high level of trust which ONR needs to have in a licensee, and which is vital in ensuring an efficient and effective working relationship. Unresolved concerns about the quality of communications from NNB GenCo to ONR may require an increased level of regulatory oversight until the path to achieving the necessary level of trust can be re-established. ONR advises that NNB GenCo address all of the identified communication shortfalls as a matter of urgency.
The findings from this intervention highlight a number of deficiencies with regard to NNB GenCo processes and performance. Individual deficiencies, taken on their own, may not be of such seriousness as to raise regulatory concern; in aggregation, however, they indicate a broader shortfall in NNB GenCo's systems and processes.
ONR acknowledges that NNB GenCo's construction management arrangements are in the early phase of being stressed and would inevitably be subject to refinement as the project progresses. The shortfalls indicated by the events discussed in this IR provide an early opportunity for NNB GenCo to identify valuable learning and implement improvements in its management arrangements before the project moves into a more complex and demanding construction phase.
The failure in communications and the consequent diminishing of regulator confidence illustrates the fragility of the bond of trust between ONR and licensee, and is a reminder of the importance of avoiding such communication failures in future.
Looking towards the next planned permissioning milestone (the start on the pumping station), ONR will want to see clear evidence that relevant processes have been strengthened and that identified deficiencies in nuclear safety culture have been suitably addressed. ONR would expect that NNB GenCo's own investigation will identify these and many more points of learning from these events and that suitable action plans will be put into effect.