Office for Nuclear Regulation

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Inspection of Licence Conditions 17 and 36 focused on Nuclear Safety Culture Development

Executive summary

Purpose of Intervention

The purpose of this ONR intervention was to undertake a planned inspection at NNB Generation Company (HPC) Ltd (NNB GenCo), Bridgewater House Office, Bristol, in accordance with ONR’s Intervention Plan for the regulation of Hinkley Point C in 2018/19.

This planned licence condition inspection was carried out by ONR organisational capability specialists to assess the progress in nuclear safety culture activities at NNB GenCo’s Delivery Command Centre, and thus to make a judgement on NNB GenCo’s compliance with Licence Conditions 17 and 36.

Interventions Carried Out by ONR

Licence Condition 17 (LC17) requires that the licensee shall: “establish and implement management systems which give due priority to safety” [and]: “within its management systems, make and implement adequate quality management arrangements in respect of all matters which may affect safety.”

Licence Condition 36 (LC36) requires that the licensee shall: “provide and maintain adequate financial and human resources to ensure the safe operation of the licensed site” [and]: “make and implement adequate arrangements to control any change to its organisational structure or resources which may affect safety.”

The inspection, which comprised discussions with NNB GenCo’s staff and examination of NNB GenCo’s documentation focused on the implementation of the Project Culture Strategy and both site plans and wider Project activities, excluding organisational learning.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable; this was not a Safety System inspection.

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

ONR inspectors consider the developments of the nuclear safety culture at NNB GenCo to be good in many areas. For instance, there is evidence of Project Culture Strategy, underpinned with an achievable Implementation plan, which has good leadership support and allocated budget. Furthermore, there is evidence of a reasonable progress on the 2018 Implementation Plan activities. In addition, key nuclear safety culture projects like Behaviours and Values for Success, Engaged Leadership, Lean and Simple, and Shared Schedule show clear commitment of NNB GenCo’s leadership.

For these reasons the ONR inspectors judged the compliance with licence condition 17 & 36 as Green (No Formal Action).

 Conclusion of Intervention

In conclusion the intervention was rated as green for this stage of the project. My findings were shared with, and accepted by the licensee.