Office for Nuclear Regulation

LC11 Assessment of HPC Emergency Arrangements

Executive summary

Purpose of Intervention

This intervention was a routine licence compliance inspection carried out to assess NNB GenCo Hinkley Point C (HPC) Ltd (NNB)’s compliance with LC 11 - Emergency Arrangements.

Interventions Carried Out by ONR

ONR carried out the following LC11; Emergency arrangements inspection:

Given that nuclear fuel has yet to be delivered to site (and will not be for some time) NNB’s current arrangements are primarily focused on ensuring that that it can appropriately respond to a construction related incident such as a fire or construction event (including industrial radiography). These arrangements must also ensure that NNB can respond appropriately in the event of an offsite release from the adjacent Hinkley Point B power station.

ONR carried out the intervention jointly with NNB’s internal regulator.

Explanation of Judgement if Safety System Not Judged to be Adequate

This was not a system-based inspection.

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

NNB has made significant progress with the rationalisation and revision of its emergency scheme documentation. However some required information has not been appropriately transferred to the new suite of documentation and some required documentation has not yet achieved the required approval status.

Appropriate facility and equipment checks are being carried out. However their thoroughness and the response to any identified defects are in some cases inconsistent.

NNB has identified a number of new required emergency scheme roles. Whilst it has made significant progress with training personnel for these roles it has not, at the time of the inspection, formally introduced these roles onto a secure 24/7 rota.

NNB and its contractors’ implementation of appropriate emergency exercise and drills have improved. This has involved testing and demonstrating their ability to respond to a variety of construction related incidents.

NNB’s and its contractors’ arrangements for informing personnel of an event or incident and securing an appropriate response were inconsistent. The emergency broadcast system was not yet installed in some areas and instead in these areas NNB relied on radios; however ONR observed that this arrangement did not appear to be consistently implemented. In addition ONR found that a number of personnel could not clearly articulate the meaning of the site alarms on site and the response expected of them.

Conclusion of Intervention

I judge that an overall inspection rating of AMBER “seek improvement” is appropriate. As such I have raised two level 3 regulatory issues to ensure appropriate regulatory oversight of the most significant required improvements in relation to LC11. These relate to ensuring the effectiveness of NNB and its contractors’ arrangements for informing personnel of an event or incident and securing an appropriate response. And, the securing by NNB of the enhanced emergency scheme staffing it has identified is required to support the increased complexity and scale of it arrangements.

For the remaining improvement areas it is ONR’s expectation that NNB’s internal assurance function will capture these and ensure close out. Therefore, ONR has raised a level 4 regulatory issue to ensure appropriate oversight of these matters.