Office for Nuclear Regulation

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Level 4 Routine licence condition 9 and 11 intervention including site meeting

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 (LC), 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’s compliance with LC 09; Instructions to persons on the site and LC 11; Emergency arrangements assessing the adequacy and effectiveness of NNB GenCo’s emergency arrangements and in particular ensuring that site personnel understand the response necessary in the event of an accident or emergency including awareness of the types and nature of the emergency alarms on the site.

In addition I held a number information sharing meetings.

Interventions Carried Out by ONR

LC 09 requires that “The licensee shall ensure that every person authorised to be on the site receives adequate instructions … [on] … the action to be taken in the event of an accident or emergency on the site.”

LC 11 requires that “ …the licensee shall make and implement adequate arrangements for dealing with any accident or emergency arising on the site and their effects.”

ONR carried out the following LC09; Instructions to persons on the site and LC11; Emergency arrangements intervention:

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

LC09; Instructions to persons on the site

NNB GenCo has expended significant effort in relation to improving site personnel’s awareness of the meaning of site alarms and the action to be undertaken in response to them. Whilst this has resulted in some improvement in awareness, this has not yet been fully effective and some further work will be required.

LC11; Emergency arrangements

NNB GenCo has significantly strengthened its assurance activities aimed at assessing its contractor’s implementation of its emergency arrangements.

NNB GenCo has sustained its enhanced emergency scheme staffing and is continuing to further strengthen its arrangements to ensure they are ready for further increases in the complexity and scale of construction.

It is evident that NNB GenCo has put in place a comprehensive exercise programme which is exercising a wide range of scenarios across its tier 1 contractors.

NNB GenCo will need to ensure that its means of communicating site alarms evolves to ensure that they remain effective as civil construction increases, in scale and complexity, including understanding the impact of the resulting structures and rooms on current communication methods.

Conclusion of Intervention

LC09; Instructions to persons on the site

Overall I judge that an inspection rating of Amber (Seek improvement) is appropriate for LC 09; instructions to persons on the site. This is because whilst NNB GenCo has clearly expended significant effort in ensuring site personnel’s understanding of the meaning of site alarms and the action to be taken in response to them leading to some improvement, based on ONR’s sampling this has yet to be fully effective and hence ONR considers that the associated extant regulatory issue cannot yet be closed.

LC11; Emergency arrangements

Overall I judge that an inspection rating of GREEN (No formal action) is appropriate for LC 11; Emergency arrangements. This is because overall I am satisfied that NNB GenCo is adequately managing its emergency arrangements and has made a number of significant improvements. I do however note that further work is required by NNB GenCo to ensure that it has in place a suitable strategy to demonstrate how it will manage the means of communicating site alarms as construction complexity increases and this is captured in an extant regulatory issue.