The Office for Nuclear Regulation's (ONR) permissioning strategy for the construction of Hinkley Point C (HPC) has identified equipment qualification (EQ) as a work stream under the 'Safety Case' cornerstone theme to gauge whether safety case claims will be met by the safety related equipment procured.
EQ is undertaken to demonstrate that the procured safety related equipment is capable of fulfilling the requirements of the safety case during normal operational conditions, after seismic events and in the harsh environments associated with certain design and beyond design basis accidents (for example loss of coolant accidents and high energy steam line breaks). As such this aspect needs to be managed during the HPC tendering process prior to the signing of contracts and is an area of ongoing interest to the ONR.
At the previous level 4 meeting held in October 2013 it was established that NNB GenCo's progress in terms of the availability of key project documents and fulfilling its Intelligent Customer (IC) role in the EQ work area had not met its or ONR's expectations. This was largely attributed to the lack of suitably experienced resource within NNB GenCo.
This level 4 meeting provided the opportunity for NNB GenCo to provide an update on EQ activities.
This meeting was held to allow ONR to gauge compliance with licence condition 19 (LC19 - Construction or Installation of New Plant) and LC14 (Safety Case).
ONR inspectors provided feedback on the update from NNB GenCo; the main topics covered included:
I, the ONR lead for the HPC EQ work stream, was supported by a specialist electrical engineering inspector. As for the previous level 4 meeting NNB GenCo's Independent Technical Assessment (ITA) lead did not attend; I noted that ONR's expectation was that ITA should be represented at all level 4 meetings.
Not applicable; system/structures-based inspection did not take place.
Six out of the seven EQ BDR deliverables have been received from the Responsible Designer on schedule; the Flamanville 3 lessons learned report was expected later in the week. The NNB GenCo review and acceptance of the various documents is understood to be on schedule for completion by the end of February. I consider a number of the deliverables to be of particular significance and will be reviewing them as part of my ongoing intervention.
I am satisfied that NNB GenCo is now taking appropriate steps to address the shortfall in EQ Intelligent Customer (IC) capability within the project. It also recognises the need to provide oversight by an external suitably qualified and experienced person for this topic in the short term - this is an area that I will continue to monitor as part of my intervention.
I noted that for design basis accidents the route for determining the equipment to be qualified is understood in that it is closely linked to the current safety categorisation and classification studies. The process for generating the list of equipment to be qualified for severe accidents however is not so clear; this will be followed up as part of normal regulatory business.
The current intent is to include the HPC specific fault studies that will be used to confirm the bounding nature of the EQ input data in the pre-commissioning safety report and not PCSR3. I consider this to be too late as all the equipment will have been procured and installed by this time. NNB GenCo agreed to consider revising the wording of the associated entry in the project risk register and I will be discussing the proposed timescales with the ONR fault studies and project inspectors.
On the basis of discussions during the meeting I am satisfied that NNB GenCo has continued to make progress in the EQ work area.
It was agreed that a Red/Amber/Green status of AMBER was still appropriate for the EQ work stream due to:
I consider an inspection rating of 4 'Below Standard' to be appropriate.
A number of level 4 actions were agreed during the meeting that will be followed up as part of routine regulatory business.
No recommendations have been made as a result of the level 4 meeting covered by this intervention report.