Office for Nuclear Regulation

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Hinkley Point C - Routine compliance inspection of licence condition 7

Executive summary

Purpose of Intervention

In accordance with the Office for Nuclear Regulation’s (ONR’s) Hinkley Point C HPC)  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 07; Incidents on the site focusing on the adequacy and effectiveness of NNB’s organisational learning processes.
In addition I held a routine information sharing meeting focusing on aspects related to temporary works.

Interventions Carried Out by ONR

LC 07 requires that “The licensee shall make and implement adequate arrangements for the notification, recording, investigation and reporting of such events occurring on the site…”

ONR carried out the following LC 07; Incidents on the site:

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

LC07 - Incidents on the site

NNB has secured improvements in the staffing of its Learning & Improvement function, which should now provide stability to enable the required improvements to the adequacy and effectiveness of its organisational processes to be secured.

Although some improvements have been made, further improvements are required to NNB's management and oversight of its event investigations and resultant actions.

NNB's internal con-conformance learning entries require review to ensure that they are being managed in an appropriate manner.

Whilst NNB has provided what appears to be a credible high level plan to secure the required improvements to its organisational learning including the deployment of an improved organisational learning tool, appropriate management oversight will be required to ensure that improvements are delivered.

Conclusion of Intervention

LC07 - Incidents on the site

I judge that overall an inspection rating of AMBER (Seek improvement) is appropriate for licence condition 07; Incidents of on the site. This is because I have identified that a number of improvements are required to ensure that NNB is effectively managing its organisational learning and associated processes.

I have raised two level 3 regulatory issues, one to address required short term improvements relating to the management of significant investigations, resultant actions and internal non-conformances. The second issue being raised to ensure appropriate regulatory oversight of NNB’s improvements to the effectiveness of its organisational learning processes, which will be facilitated by the introduction of its new organisational learning tool.