Office for Nuclear Regulation

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Hinkley Point C - Licence Condition 19 compliance 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.

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:

The following guidance was used in this intervention:

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

NNB demonstrated evidence their gate review process which seeks early contractor engagement with designers through to handover from TMA to SET via a dedicated meeting which I considered adequate. NNB GenCo delivery integration showed good ownership of the tracking tools via PowerBi for civil engineering works.

At the intervention, there was a lack of clarity regarding ownership and governance of the decision to split EDR packages. Whilst I did not have any significant concerns regarding the splitting of CRX EDRs, ONR has previously noted a lack of governance and oversight regarding the splitting of EDR packages (2018/274784) and no improvement in this area was evident to ONR during this intervention. As such, I have raised a level 4 regulatory issue.

I observed that there remain challenges, which were noted in a previous ONR intervention (2018/274784) to achieve delivery of the civil engineering design by TMA to site engineering within NNB GenCo’s desired T-3 timescales, meaning construction teams have a compressed timescale to carry out their activities I have raised a level 4 regulatory issue to capture this.

Conclusion of Intervention

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 the delivery of civil engineering work packages to site construction teams. This is because I found NNB GenCo to be compliant with its legal duties with only minor areas for potential further improvement. However, I have raised a level 4 regulatory issue to ensure delays to design delivery are being appropriately managed by NNB GenCo TMA and a level 4 regulatory issue to capture governance of the splitting of EDRs.