Office for Nuclear Regulation

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Hinkley Point C - LC6 and LC19 inspection

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 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 a routine licence condition inspection carried out to assess NNB GenCo (HPC)’s compliance with licence condition 19; Construction or installation of new plant and licence condition 06; Documents, records, authorities.

In addition I held short meetings with NNB GenCo’s Heatsink and Nuclear Island projects to discuss progress and forward work activities, I also held a short discussion with relevant NNB GenCo personnel to discuss NNB GenCo’s progress with a number of regulatory issues.

Interventions Carried Out by ONR

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.”

ONR carried out the following LC 19; Construction or installation of new plant inspections:

LC6 requires that ‘the licensee shall make adequate records to demonstrate compliance with any of the conditions attached to this licence. .” and “that every record made, every authority, consent or approval granted and every direction or certificate issued in pursuance of the conditions attached to this licence is preserved for 30 years or such other periods as ONR may approve.”

ONR carried out a half day LC06; Documents, records, authorities and certificates inspection focusing on the adequacy of NNB GenCo’s and its contractor’s management of concrete samples and associated records.

The following guidance was used in these interventions:

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

LC19 - Management and installation of steel reinforcement used in nuclear safety related structures at the Hinkley Point C site.

ByLor management of rebar is generally to high standard with of appropriate receipt, tracking and fabrication checks.

ONR observed that there were differences in the understanding and expectations relating to the fabrication of reinforcement between the fabrication yard and insitu fabrication on the nuclear island. Whilst ONR was content that these were not currently having a significant effect on nuclear safety, ONR considers that NNB GenCo should ensure that it confident that ByLor’s processes ensure consistency and the sharing of good practices relating to reinforcement management.

LC19 - Adequacy and implementation of NNB GenCo’s Request for Information (RFI) process.

ONR observed that whilst NNB GenCo are making progress in developing the RFI process there is a lack of maturity of the RFI process with improvements required regarding the clarity of the RFI process in a number of areas, such as scope, routing/approvals of RFIs and consistency of use.

ONR noted that is some instances RFIs had not been supported by required design evolution notes (DENs), however there was no evidence that this had impacted nuclear safety.

LC19 - Adequacy of NNB GenCo’s implementation of its “Design Authority Site Assurance of Construction Surveillance Activities” programme.

NNB has not yet adequately implemented its Technical Management and Acceptance programme of assurance of construction surveillance activities in accordance with its own programme.

Whilst it is positive that NNB GenCo now has a plan in place to address this issue and a number of other identified improvements, continued focus will be required to ensure that these improvements are secured in a timely fashion.

LC06 - Adequacy of NNB GenCo’s and its contractor’s management of concrete samples and associated records.

ByLor and KierBam JV laboratories were found to be appropriately managing concrete samples and associated records with evidence that appropriate concrete sample records are being produced in both laboratories.

NNB GenCo has not yet clearly defined its life time quality records in relation to concrete samples and as such at the time of inspection none are currently held by NNB GenCo.

ByLor is currently storing all concrete sample records in paper format onsite and due to the fact none have yet been transmitted to NNB GenCo (due to lack of clarity in NNB GenCo’s lifetime quality records requirements) there exists a risk of loss of these records.

Conclusion of Intervention

LC19 - Management and installation of steel reinforcement used in nuclear safety related structures at the Hinkley Point C site.

I judge that overall an inspection rating of GREEN (No formal action) is appropriate for licence condition 19; Construction or installation of new plant in relation to reinforcement. This is because overall I found NNB GenCo and ByLor were appropriately managing reinforcement to ensure that it is installed as per design. I have however raised a level 4 regulatory issue requiring that NNB GenCo ensures that ByLor has a suitable procedure/process or other document that ensures consistency of standards and thereby captures learning and good practices regarding the fabrication of reinforcement across the site.

LC19 - Adequacy and implementation of NNB GenCo’s Request for Information (RFI) process.

I judge that overall an inspection rating of AMBER (Seek improvement) is appropriate for licence condition 19; Construction or installation of new plant regarding NNB GenCo’s RFI process. As such I have raised a level 4 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 ONR have identified which further improvement regarding maturity of the RFI process including scope and consistency or use.

LC19 - Adequacy of NNB genCo’s implementation of its “Design Authority Site Assurance of Construction Surveillance Activities” programme.

I judge that overall an inspection rating of AMBER (Seek improvement) is appropriate for licence condition 19; Construction or installation of new plant regarding NNB GenCo’s implementation of its design authority site assurance of construction surveillance activities programme. 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 primarily due to NNB GenCo’s failure to adequately implement its site assurance of construction surveillance  activities programme

LC06 - Adequacy of NNB GenCo’s and its contractor’s management of concrete samples and associated records.

I judge that overall an inspection rating of AMBER (Seek improvement) is appropriate for licence condition 06; Documents, records, authorities and certificates in relation to NNB GenCo’s responsibilities for the management of concrete sample records. As such I have raised a level 3 regulatory issue ensure appropriate regulatory oversight of NNB GenCo’s improvements in this area. This is due to there being a number of areas ONR have identified which further improvement, particularly regarding NNB GenCo’s specification and implementations of its life time quality record requirements in relation to concrete sample records.