Office for Nuclear Regulation

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Hinkley Point C - Planned intervention

Executive summary

Purpose of Intervention

In accordance with the Office for Nuclear Regulation’s (ONR’s) Hinkley Point C Construction inspection plan, ONR performs a series of planned licence compliance and crosscutting interventions, 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.

This cross cutting intervention assessed how key aspects of NNB GenCo’s site capabilities and functions are developing to ensure appropriate control & co-ordination of site activities.  Control and co-ordination of site activities are important items to ensure effective site operation and contribute to both immediate site safety and construction quality which impacts future nuclear safety. 

As part of this cross-cutting intervention the following licence condition compliance inspections were carried out, LC10; Training, LC12; Duly authorised and other suitably qualified and experienced persons, LC17; Management systems, LC36; Organisational capability.

Interventions Carried Out by ONR

I carried out a two day crosscutting intervention with the ONR HPC Organisational Capability lead inspector and the ONR HPC Civil Engineering Construction Assurance lead which included licence compliance inspections against licence conditions 10, 12, 17 and 36 utilising the following ONR inspection guidance:

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A as this was not a safety systems inspection.

Key Findings, Inspector's Opinions and Reasons for Judgements Made

Site Capability and Integration

I consider that there are effective processes for managing the control and co-ordination of site activities at this point in time. However these will be required to rapidly mature as site activities increase. As such NNB need to ensure appropriate forward work/development plans are in place to ensure key functions and processes mature to support major uplifts in site activities.

LC 10 and 12

NNB was able to demonstrate that it was ensuring that suitable qualified and experienced persons are carrying out responsibilities relating to site integration and industrial safety. Whilst NNB’s current training management arrangements are broadly adequate for this point in time, ONR observed that the current training management tools will need to be significantly developed as the project progresses.

LC 17

Overall whilst I consider that NNB was able to demonstrate that adequate management systems were in place, I consider that the guidance with regards to the functioning of Multi-Disciplinary Teams (MDTs) and particularly the MDT meetings could be improved to ensure they consistently implement appropriate challenge and project leadership.

LC 36

NNB has established an appropriate nuclear safety baseline and is evolving this baseline to take into account the changing nuclear safety significance of key roles (such as those in the site technical team) as the project moves to the delivery phase in earnest and changes are being managed through its LC36 arrangements.

Conclusion of Intervention

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 conditions 10 and 12; Training and Duly Authorised and Other Suitably Qualified and Experienced Persons, licence condition 17; Management Systems and licence condition 36; Organisational capability.  This is because I found NNB to be compliant with its legal duties with only relatively minor areas for further improvement being identified.

I consider that NNB was able to demonstrate that it has effective processes for managing the control and co-ordination of site activities at this point in time. However these will be required to rapidly mature in a number of areas as site activities increase and as such NNB need to identify what level of maturity/deployment of organisation capability and processes is required prior to major uplifts in site activities.