Office for Nuclear Regulation

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Hinkley Point C - LC6 intervention

Executive summary

Purpose of Intervention

This intervention was conducted at the Licensee’s Bridgwater House offices and undertaken as part of the ONR Intervention Plan (CM9 2019/95951, ONR HPC Project Intervention Plan beyond JO).

Interventions Carried Out by ONR

We conducted a Licence Condition (LC) 6 (Documents Records, Authorities and Certificates) compliance inspection on the implementation of the licensee’s arrangements for the licence condition, which also included evaluating the Licensee’s current (interim arrangements) document management system arrangements.

I am satisfied that the principal objectives set for this intervention have been achieved. 

The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.

This intervention used the following guidance as relevant good practice:

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

This was an office based intervention, which consisted of presentations, observations, sampling of evidence provided and discussions. Overall the arrangements demonstrated were considered appropriate; although the true adequacy of the arrangements deployed in the field was not assessed during this intervention. ONR have an intervention planned on the HPC site later in 2019, to assess the adequacy of implementation of the LC 6 arrangements. 

The knowledge and experience of the NNB team interviewed during the intervention was considered good.

ONR noted the induction arrangements for new site Document Controllers were good, providing a systematic on-boarding training and competency assessment. However, this is a local arrangement and not part of HPC’s formal competency arrangements.

ONR also positively noted the recent engagement of the senior leadership to support addressing the shortfalls in LC6 arrangements. However, this leadership support needs to be sustained to embed the required improvements. 

During the intervention ONR sampled project records, such as the ‘end of manufacturing records’ (EOMR) and Project Quality Plans and noted a number were  overdue.

ONR noted a fragmented approach to improvement, with four live improvement plans currently in-place. Recognising the delays in resolving the related Regulatory Issue 7042, ONR would recommend a more integrated approach be adopted. 

NNB anticipate a significant increase in documents that will need to be managed going forward, which is strongly linked to the projected increase in manufactured items.

NNB are in the process of introducing phase 2 of a new records management software platform at the end of this year. This is likely to affect a large number of users from within NNB, their Responsible Designer and their Supply Chain.  ONR noted this will need a high level of management attention to ensure appropriate standards are maintained. 

ONR have an holistic concern relating to the sustainability of L6 related improvements across the HPC project, based on the demonstrated performance over the last 12 months.

ONR would recommend improvements in the arrangements for appointing the LC6 owner, which include clear accountabilities and authorities for the role. There should be consideration given to how the LC6 owner demonstrates the adequacy of NNB’s management arrangements and how they comply with LC6 requirements.

Conclusion of Intervention

Based on the intervention of HPC’s LC6 arrangements, which included a selected sample of HPC’s records, ONR consider the arrangements to be appropriate for a project of the complexity of HPC. NNB also have improvement plans in place to address a number of identified gaps and shortfalls. However, we considered that the current LC6 arrangements are not sufficiently implemented based on the selected sample, and improvements activities identified in the action plans are not embedded. The effectiveness of their arrangements needs to be demonstrated and sustained, particularly as the workload is forecasted to significantly increase. In our opinion shortfalls are evident in the implementation of the arrangements, which fail to meet the expectation under LC6.      

ONR also acknowledge and have taken due cognisance of the findings of the NNB’s Independent Nuclear Assurance (INA) report,  titled ‘LC6 Assessment of the Main Civil Programme’, dated 27 July  2019, (100198522). INA assessed NNB’s wider LC6 compliance as Red.

ONR will seek to accelerate the aforementioned further planned intervention to assess the implemented LC6 arrangements on-site. The outcome of this on-site intervention will inform ONR’s view on the rating of compliance against the requirements of LC 6 and inform any further action.

ONR have made two judgements during this intervention, firstly based on the office based sample of NNB’s  LC 6 arrangements for Inspection of Documents Records, Authorities and Certificates; ONR consider this to be currently rated as Amber. However, this is based on a small sample of records that were available for review during this intervention. ONR will seek further assessment of the adequacy of implementation through the accelerated on-site intervention, where a larger sample of records can be reviewed.

Secondly, ONR judged that NNB’s has sufficient oversight and control of their current records management platform, until the introduction of phase 2 of Teamcentre. Therefore ONR have rated this as Green with no formal action.