In accordance with the Office for Nuclear Regulation’s (ONR’s) Hinkley Point C Construction inspection plan, ONR performs a series of planned compliance inspections of identified licence conditions, to ensure that NNB Generation Company (HPC) Ltd (NNB GenCo(HPC) Ltd), is proportionately and adequately developing and implementing its licence compliance arrangements commensurate to the current stage of the project.
These planned, licence condition inspections were carried out to assess NNB GenCo’s compliance with licence condition 07; Incidents on the site, licence condition 09; Instructions to persons on the site and licence condition 11; Emergency arrangements.
LC 07 requires NNB GenCo(HPC) to "…make and implement adequate arrangements for the notification, recording, investigation and reporting of such incidents occurring on the site…"
LC 09 requires NNB GenCo(HPC) to "…ensure that every person authorised to be on the site receives adequate instructions (to the extent necessary having regard to the circumstances of that person being on the site) as regards the risks and hazards associated with the plant and its operation, the precautions to be observed in connection therewith and the action to be taken in the event of an accident or emergency on the site."
LC 11 requires NNB GenCo(HPC) to "…make and implement adequate arrangements for dealing with any accident or emergency arising on the site and their effects."
I carried out two one day licence compliance inspections against licence conditions 07 and 11 and a half day inspection against licence condition 09 utilising the following ONR inspection guidance:
and OE Processes
In addition I undertook a number of information sharing sessions during this intervention.
N/A as this was not a safety systems inspection.
Overall I judge that NNB has an adequate process for the reporting of events and their investigation with the exception of the following relatively minor areas for improvement:
Overall I consider that the combined site specific and generic aspects of the NNB induction process is providing adequate instructions to persons on site and providing a good basic understanding of the expected behaviours (including nuclear safety considerations) and potential risks at the Hinkley Point C construction site.
I consider that NNB was able to demonstrate that it is deploying appropriate muster facilities whose design and operation is being optimised using learning from drills and exercises.
NNB’s deployment of a full time onsite fire response capability is a significant improvement and should result in a significant uplift to its overall emergency response capability.
NNB is appropriately developing its emergency arrangements commensurate with project requirements as new workfaces and activities are commenced.
On the basis of the evidence gathered during this inspection, I judge that an inspection rating of GREEN (No formal action) is appropriate for licence condition 09; Instructions to persons on the site and licence condition 11; Emergency arrangements. This is because I found NNB to be compliant with its legal duties with only minor areas for further improvement being identified.
With regards LC07; Incidents on the site, whilst I found that NNB was compliance with its legal duties I identified some minor compliance shortfalls with respect to its consistency of event coding and the clarity NNB’s guidance linking required investigation levels (scope and depth) to the significance of events. Hence whilst I judge that an inspection rating of GREEN (No formal action) remains appropriate, I have raised level 4 regulatory issues to ensure that these relatively minor compliance shortfalls are appropriately addressed.