Office for Nuclear Regulation

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LC 17 - Integrated Management System (IMS) arrangements for site delivery

Executive summary

Purpose of Intervention

This intervention was conducted at NNB Generation Company (HPC) Limited’s (NNB GenCo) Hinkley Point C (HPC) site and undertaken as part of the ONR intervention plan, HPC Project Intervention Plan beyond J0.

Interventions Carried Out by ONR

We conducted a Licence Condition (LC) 17 (Management Systems) compliance inspection. This involved sampling the adequacy and effectiveness of arrangements for selected NNB GenCo Integrated Management System (IMS) construction procedures relating to site delivery.

The key focus of the intervention was to assess how the process owners and process leads are assured that their respective procedures are being adequately implemented and deployed within the overall IMS arrangements for site delivery.

We assessed NNB GenCo’s LC arrangements against relevant good practice from ONR regulatory guidance.

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

From the evidence sampled and discussions held, we found that the licensee personnel interviewed during the inspection had a good understanding and knowledge of the processes, and demonstrated they have recognised and identified areas of improvements and learning.

Throughout the areas selected and examined, the licensee appeared to be adequately managing the process changes and deployed adequate oversight and assurance arrangements.

We consider that based on the evidence sampled and interactive discussion, the site based assurance activities described by the licensee provide confidence that the arrangements for the areas examined are being adequately managed.

ONR are content that the licensee has put in place the Civils Programme delivery portal and oversight arrangements for document completion.

From the evidence sampled and discussions held, it was unclear how the licensee’s central functions such as Quality and Assurance gain confidence that the IMS arrangements for site delivery are adequate including the provision of Integrated Assurance Assessments.

Conclusion of Intervention.

Overall I judge that an inspection rating of GREEN (No formal action) is appropriate for   LC17 – Management Systems. This is because based on the areas sampled during the inspection, I am satisfied that the licensee has a good understanding of processes and is progressing the delivery of the required improvements.

ONR will consider a proportionate regulatory response and follow up in future planned ONR interventions on how the licensee Quality and Assurance central functions gain confidence that the IMS processes and arrangements for site delivery are adequate, including the provision of Integrated Assurance Assessments in line with the programme requirements.