Hinkley Point C - LC5 and LC8 intervention
- Site: Hinkley Point C
- IR number: 18-011
- Date: August 2018
- LC numbers: 5, 8
Purpose of Intervention
In accordance with the Office for Nuclear Regulation’s (ONR) Hinkley Point C (HPC) construction inspection plan, ONR performs a series of planned compliance inspections of identified Licence Conditions (LCs) 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.
These planned Licence Condition inspections were carried out to asses NNB GenCo’s compliance with LC 5 (Consignment of nuclear matter) and 8 (Warning notices). The inspections were focused on the licensee’s improvement to its LC5 and LC8 arrangements made following ONR’s interventions in September 2017 and February 2018, respectively.
Interventions Carried Out by ONR
LC 5 requires the licensee to:
- “not consign nuclear matter (other than excepted matter and radioactive waste) to any place in the United Kingdom other than a relevant site except with the consent of ONR.”
- “keep a record of all nuclear matter (including excepted matter and radioactive waste) consigned from the site […]”.
- “ensure that the aforesaid record is preserved for a period of 30 years from the date of despatch […] except in the case of any consignment or part thereof subsequently stolen, lost jettisoned or abandoned, in which case the record shall be preserved for a period 50 years […].”
LC8 requires the licensee to “[…] ensure that suitable and sufficient notices are kept on the site for the purposes of informing persons thereon of each of the following matters, that is to say:
- The meaning of any warning signal on the site;
- The location of any exit from any place on the site, being an exit provided for use in the event of an emergency;
- The measures to be taken by such persons in the event of fire breaking out on the site or in the event of any other emergency.
And that such notices are kept posted in such positions and in such characters as to be conveniently read by those persons.”
I carried out a one day LC compliance inspection against LC5 and LC8, utilising the following ONR Technical Inspection Guides (TIGs):
- LC5 – Consignment of nuclear matter;
- LC8 – Warning notices.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
LC5 compliance inspection
On the basis of the evidence sampled during this inspection, I judge that:
- NNB GenCo has adequately addressed the actions raised during the September 2017 inspection, that is to say:
- NNB GenCo has now implemented adequate retention periods for nuclear matter consignment records, with a minor area for improvement identified;
- Nuclear matter consignment records have been completed in line with the licensee’s arrangements;
- NNB GenCo arrangements now ensure compliance against LC5(3) by giving instructions on the management of stolen, lost, jettisoned or abandoned consignments.
- NNB GenCo and its contractors’ implementation of the revised LC5 compliance arrangements is adequate and demonstrates good oversight.
LC8 compliance inspection
Based on the evidence sampled during this inspection, I conclude that:
- NNB GenCo’s updated arrangements and their implementation, including by their contractors, is compliant with the requirements of LC8; and that
- NNB GenCo has completed the actions identified in Regulatory Issue 6167, that is to say:
- NNB GenCo revised LC8 compliance arrangements now ensure that buildings are not occupied prior to these arrangements being implemented;
- LC8 compliance arrangements are now fully implemented by NNB GenCo’s contractors, and oversight is exercised in a proportionate manner;
- NNB GenCo’s checking requirements have been demonstrably improved, based on my inspection of the North Office warning notices.
I therefore recommend closure of Regulatory Issue 6167.
Conclusion of Intervention
Based on the evidence gathered during this inspection, I judge that an inspection rating of Green (No formal action) is appropriate for LC5 (Consignment of nuclear matter) and LC8 (Warning notices). This is because I found NNB GenCo to be compliant with its legal duties.