Modifications to the Hinkley Point C (HPC) design are currently managed through NNB Generation Company (HPC) Ltd’s, furthermore known as the HPC licensee, Licence Condition 20 (LC20) arrangements: Modification to design of plant under construction. As part of these arrangements a Licence Summary Statement (LSS) is produced (for category 1 and 2 modifications) that is intended to provide the background, technical descriptions and high level safety case claims and arguments which will support the modification.
Due to the current stage of HPC project not all of the evidence is available to justify the modification proposed. Hence the LSS provides a list of future intelligent customer activities, which are required to generate the required evidence to justify the proposed modification.
To enable ONR to agree to a proposed modification, confidence is required that the HPC licensee has adequate arrangements in place to capture, manage and deliver in a timely manner all future activities.
As capturing and managing future intelligent customer activities was deemed important it was considered proportionate to conduct an intervention on this aspect of the LC20 arrangements. Therefore a team of two inspectors attended the HPC licensee’s offices in Bristol to discuss and review the processes that the HPC licensee has in place for capturing and managing those future intelligent customer activities deemed important.
The objectives of this intervention were to gather evidence first hand, to form a judgement on the HPC licensee’s arrangements to capture, manage and deliver future intelligent customer activities specified within an LSS produced in accordance with the LC20 arrangements. Specifically, the objectives were to:
From this intervention I observed the process that the HPC licensee has chosen to capture, manage and deliver future intelligent customer activities. I am content that whilst this process uses a system not intended for this purpose, the process appears robust. I observed evidence of its use and whilst I noted some areas where the process could be strengthened, the general intent and use is adequate. A set of observations were made to highlight those areas that, in my opinion, could be strengthened:
In addition, I highlighted the following areas of good practice:
On the basis of the evidence gathered during this intervention, I judge that an inspection rating of GREEN (no formal action) is appropriate for LC20 (Modification to design of plant under construction). This is because I found the HPC licensee’s arrangements to capture, manage and deliver future intelligent customer activities to be adequate with only minor areas for further improvement.
For those areas where I have made observations, these will be discussed during regular planned level 4 meetings with the HPC licensee, and monitored via a level 4 meeting action for the HPC licensee to report back on its response to the observations.