This intervention was a Licence Condition (LC) 17 assessment of the adequacy of the Hinkley Point C (HPC) Site Independent Challenge Function against relevant good practice.
LC 17 requires the licensee to establish and implement management systems which give due priority to safety. As part of these nuclear safety prioritised management systems ONR expects the licensees to have an adequate independent challenge capability.
NNB carries out its internal challenge capability through an internal regulator, Internal Nuclear Assurance (INA). INA reports independently of the delivery functions. It is organised with a HPC Site Team, a Technical Group, a Corporate Team and a Supply Chain Team. This intervention was focused upon the HPC Site Team.
I observed that the Site INA Team has a number of strengths. All their stakeholders welcomed their advice and challenge. They particularly valued INA’s informal radiography advice. I consider that the Site INA Team has developed a positive relationship with their site and Site INA is using the relationship to influence nuclear safety. I judge that this meets the requirements of relevant good practice for an independent challenge function.
However, I have observed some potential risks to sustaining the Site INA Team’s effectiveness. These are not currently impacting upon their ability to independently challenge. I will engage with INA to ensure that I am updated on progress with these observations at the next INA Level 4.
One area has not met ONR’s expectations and is impacting upon INA’s effectiveness. This is INA’s continued engagement with their advice following the completion of their formal assessments. Site INA relies upon OLIM to track actions. However, my sample has shown that this is not entirely effective at ensuring adequate action completion. Therefore I have raised a level 4 regulatory issue for INA to improve their oversight and engagement of these issues.
The Site INA Team has met the requirements of relevant good practice and is adequately carrying out an internal challenge function. Therefore I have rated this intervention GREEN, no formal action. I will engage with the site INA team to address the regulatory issue and I have a number of observations that I will monitor through my routine level 4 meetings.