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 comprised an information gathering inspection carried out to assess NNB GenCo’s compliance with licence condition 19; construction or installation of new plant, focusing on the site implementation of arrangements for construction activities. This intervention follows on from a previous intervention. Information gathering was undertaken to inform ONR’s construction assurance permissioning assessment. As such, this intervention was not awarded an inspection rating.
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 GenCo’s non-conformance processes in relation to the on-going construction activities.
The following guidance was used:
This was not a system-based inspection
There has been significant growth on site in terms of number and size of open working areas and pedestrian access arrangements between working areas. The growth of these areas are resulting in some good practices but also areas where NNB GenCo recognises improvements are required to maintain control of the work and to ensure sustained improvement that is scalable to address the work demand in the months ahead and following nuclear island concrete (NIC) permissioning. There were some lower than expected housekeeping standards and incorrect storage in designated areas observed, which NNB GenCo committed to action resolution of whilst on site.
Whilst the site is currently operating with what NNB GenCo presents as an adequate resource, there was evidence of continuing resourcing issues related to the site interface with the Technical Management and Acceptance (TMA) team and Internal Assurance teams specifically observed in this intervention.
The intervention was a useful fact finding exercise with significant information presented in a short period of time. This has informed ONR’s construction assurance assessment for NIC and will aid in identifying areas for focus in the future intervention strategy. ONR noted that the amount of work undertaken on site has increased significantly since opening up the Unit 2 excavation areas. There also remain wider concerns around the scalability of site arrangements currently in place, alongside wider concerns around site resourcing issues, which is covered by an existing Level 3 ONR Regulatory Issue.