This report records the key points raised in the Office for Nuclear Regulation's (ONR) LC19 site intervention held on 5th and 6th June 2017.
This intervention follows the reactive, unplanned intervention for 'Hinkley Point C (HPC): NNB GenCo decision to proceed with First Nuclear Safety Concrete', which concluded with ONR providing feedback to Nuclear New Build Generation Company (NNB GenCo) on 10.05.17.
The licensee, NNB GenCo, made the decision to halt Quality Related Activities (QRA) at HPC and have undertaken an Apparent Cause Investigation (ACIN) and other lessons learnt workshops and reviews in light of activities in the W1 area ('HGE' Technical Gallery). These activities have identified a number of actions, recorded in the “QRA Restart action tracker”. The restart of QRA was subject to a NNB GenCo review to confirm that sufficient progress had been made against the actions identified, including completion of all 'Priority 1' tasks. NNB GenCo authorised the restart of QRA, with blinding concrete poured on 04.06.17.
The intent of this intervention is to sample activities in the QRA Restart Action Tracker, and make a judgement on their impact on site as a result.
This intervention is in line with :
The Intervention Record (IR) “Hinkley Point C: NNB GenCo decision to proceed with First Nuclear Safety Concrete (FNSC)”, ONR-NR-IR-17-001 Revision 0 (TRIM 2017/163461) raised Level 3 Issues for LC6, LC17, LC19 and LC20.
This LC19 intervention addresses some but not all aspects of the wider LC19 Issue. This is intended to inform the ONR with progress of site activities related to restart of QRA, with judgements made on NNB GenCo actions to improve site arrangements following the FNSC intervention.
The intervention was held at Hinkley Point C site and included a meeting to update ONR on the progress of the QRA Restart Action Tracker. The second day included a half day site visit followed by meeting the Site Technical Team to discuss specific surveillance documentation improvements and the investigation of NCR issues around substitution concrete works in W1, related to the ONR intervention 'decision to proceed with FNSC'.
The intervention provided ONR with site progress information with a focus around the activities as stated in the QRA Action Tracker. NNB GenCo provided examples of improvements especially related to provision of clarity around technical specification requirements. These clarification documents have been implemented on site. This is one example of an improvement implemented by NNB GenCo, as identified on the QRA Restart Tracker. The other items on this tracker had been completed with sufficient progress and evidence for NNB GenCo to believe they were ready to restart the QRA.
The information gathered since FNSC intervention will inform the ONR strategy for site interventions up to Nuclear Island consent.
This intervention site visit was limited to observing QRA relating to the 'HGS' (drainage gallery), which was being undertaken in the W2 area (see Figure 1 for plan of 'W#' areas), with pedestrian access through W5 / W8 / W9 areas.
The personnel who presented the restart of QRA tracker demonstrated how seriously the site has taken the review of W1 works. The prioritisation of the actions has been reviewed by ONR Site Inspector. I was sampling the impact of some actions on site, namely the improvements to quality records. I was presented with the demonstration of improvements to the quality records, and the 'first use' of these improved documents in W2.
NNB GenCo displayed humility across all levels of the organisation regarding the response to the ONR intervention for 'decision to proceed with FNSC'. NNB GenCo personnel had a positive attitude to gaining the most lessons from the W1 work as an experience to implement improvements and prevent reoccurrence. NNB GenCo recognise the W1 area had some ground condition characteristics that are not replicated elsewhere on the Nuclear Island, but were still keen to demonstrate appropriate actions have been taken to continue with QRA.
NNB GenCo combined this approach with the reinforcement of the message of individual empowerment and clarity around the process of escalation to support the genuine sense of pride of working on the HPC project which drives the desire to 'do the right thing'. These are all positive steps to increase regulator confidence going beyond the restart of QRA, hence the Green RAG (Red Amber Green) status for this individual LC19 intervention report. NNB GenCo recognises that there are still Priority 3 actions on the tracker to be completed, as well as actions identified elsewhere that will support the 'path to green' for the wider LC19 Issue.
Separately, the W1 area investigation results are ongoing. These may not inform NNB GenCo with a full and complete understanding of the condition and location of the substitution concrete under W1 HG-06, due to the locations of the proposed test sites. The results of the investigation will be discussed with ONR in the LC19 intervention planned for August to further inform the ongoing wider LC19 Issue. I have raised a Level 4 Issue as part of this intervention to capture the ongoing interest ONR has in the investigation.
The Green RAG (Red Amber Green) status for this intervention is a reflection of the progress made on the sample of completed Priority 1 activities from the QRA Restart Action Tracker and their impact on the site works. The improvements in NNB GenCo documentation used to instruct Tier 1 Contractors will assist NNB GenCo to control and manage activities.
The Green RAG status reflects NNB GenCo's recognition of the need to clarify and inform personnel about the escalation process and the activities undertaken to emphasise the individual and personal empowerment message. This was further supported by the introduction of the 'PMI Impact Assessment' process allowing Tier 1 contractors to raise concerns with Project Management Instructions (PMI) issued by NNB GenCo.
This judgement of this intervention of limited scope concluding as a Green RAG status is based on the progress regarding visibility and clarity of processes. The actual implementation of the escalation process and use of PMI impact assessments have yet to be demonstrated on site but will be tested as construction continues.
The W1 area investigation work falls outside the scope of this intervention record as the testing and results were not available for discussion. In this record I have raised a Level 4 issue and rated it as amber regarding the resolution of the W1 FNSC substantiation which is still to be completed by NNB GenCo. The investigation report is due end of July 2017.
NNB GenCo's Apparent Cause Investigation (ACIN), the ONR 'decision to proceed with FNSC' Intervention Record and other workshops and reviews have identified other concerns. Some of these are captured outside the 'Priority 1' (P1) and 'Priority 2' (P2) actions in the QRA Restart Action Tracker which has been the focus of this intervention. These other activities are therefore outside the scope of this individual LC19 intervention, therefore the RAG status for the wider LC19 Issue remains Amber.