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 condition (LC) compliance arrangements commensurate to the current stage of the project.
This intervention was part of a multi-part intervention to examine the adequacy of NNB GenCo’s implementation of its LC17 compliance arrangements. The intervention was undertaken in order to gain confidence that the low voltage (LV) switchgear have been subject to an appropriate qualification test regime and review of test results, such that it is able to fulfil the safety case requirements associated with the equipment.
LC17 requires the licensee to make and implement adequate quality management arrangements in respect of all matters, which may affect safety and the following guidance, was utilised:
N/A as this was not a safety systems inspection.
NNB GenCo and its counterparts in Edvance provided a clear demonstration of how they manage oversight of the qualification testing of LV switchgear to ensure that the equipment complies with the test specification and is capable of performing its safety related duty.
NNB GenCo provided evidence to show that it has appropriate understanding of qualification test requirements and that the LV switchgear are subjected to appropriate qualification tests and the results are acceptable.
ONR queried why Direction Industrielle (DI) was not in attendance to provide oversight of the LV switchgear testing. NNB GenCo stated that DI was tasked with oversight of routine manufacturing testing only.
ONR observed that NNB GenCo and Edvance demonstrated a questioning attitude when discussing procedures and results with ABB.
No non-conformances were noted during the tests witnessed.
I judge that overall an inspection rating of GREEN (no formal action) is appropriate for licence condition 17, management systems. This is because I found NNB GenCo to be compliant with its legal duties. However, I note that further clarification is required on the role of DI and I will follow this up through my routine Level 4 meetings.