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), is proportionately and adequately developing and implementing its licence compliance arrangements commensurate to the current stage of the project.
This intervention included routine licence condition inspections carried out to assess NNB GenCo’s compliance with licence conditions 07; Incidents on the site and 19; Construction or installation of new plant.
In addition ONR carried out a routine LC19 construction assurance, information gathering intervention which is used to inform ONR’s construction assurance permissioning assessment. As such this aspect of the intervention was not awarded an inspection rating.
LC 07 requires the licensee to “make and implement adequate arrangements for the notification, recording, investigation and reporting of such incidents occurring on the site…”
LC19 requires that “Where the licensee proposes to construct or install any new plant which may affect safety the licensee shall make and implement adequate arrangements to control the construction or installation.” The focus of this LC19 intervention was the adequacy of NNB GenCos’ Non-conformance report (NCR) and field change request (FCR) processes.
ONR carried out two one day licence compliance inspection against licence conditions 07 and 19, with the LC07 compliance inspection being carried out jointly with the Environment Agency utilising the following ONR inspection guidance:
In addition ONR specialist inspectors carried a one day LC19 construction assurance intervention utilising the following guidance:
The results of this information gathering intervention are not reported further in this executive summary.
ONR also carried out a number of routine information sharing sessions.
N/A as this was not a safety systems inspection.
NNB GenCo has made a number of improvements to its LC07 compliance arrangements including improved categorisation of learning reports and improvements to NNB GenCo’s industrial and environmental event reporting tool – SELMA.
NNB GenCo has self-identified a number of areas requiring improvement however progress with addressing these areas had not met NNB GenCo’s or ONR’s expectations.
This appeared to be due, in part to the impact of reorganisations and recruitment issues. I note however that NNB GenCo has now made progress in this area and it had recently appointed a learning and improvement lead who is tasked with delivering NNB GenCo’s LC07 improvement activities. At the time of the inspection it was evident that NNB GenCo was now taking steps to address its improvement areas.
NNB GenCo will need to ensure that its proposed improvement activities secure a number of improvements including improving the management of its event investigations and resultant actions and its oversight of non-investigation related actions.
NNB GenCo has made significant improvements to its management of both non-conformance reports and field change requests, with evidence of improving performance in a number of areas, however continued focus will be required to ensure sustained improvement.
ONR observed that NNB GenCo had in general improved its categorisation justifications, however ONR did observe some instances were further improvement could be made. Discussions with relevant NNB GenCo staff demonstrated that they had good knowledge and understanding regarding the correct application of NNB GenCo categorisation guidelines.
It was evident that NNB GenCo and its’ current key tier 1 contractors have invested significant effort in improving the implementation of the FCR and NCR processes, however it is clear that NNB GenCo will need to ensure that it extracts this learning and ensures it is used to aid future contractors to efficiently and effectively engage with NNB GenCo’s NCR and FCR processes as they mobilise to site.
I judge that overall an inspection rating of AMBER (Seek improvement) is appropriate for licence condition 07; Incidents on the site. As such I have raised a level 3 regulatory issue to ensure appropriate regulatory oversight of NNB GenCo’s improvements in this area. This is due to there being a number of areas which both NNB GenCo and ONR have identified which further improvement, particularly regarding NNB GenCo’s management of investigations and learning report actions.