This intervention was conducted at the NNB’s HPC Site Construction Site and undertaken as part of the ONR Intervention Plan, HPC Project Intervention Plan beyond J0.
We conducted a Licence Condition (LC) 6 (Documents Records, Authorities and Certificates) compliance inspection. This involved sampling NNB and their contractors current arrangements for the provision of records to demonstrate that their construction works met the safety case requirements.
We assessed NNB’s arrangements against relevant good practice within ONR regulatory guidance.
ONR are encouraged by NNBs proposal to appoint a new Head of Records, who will be accountable as the LC 6 owner. We welcome NNB’s records partitioning strategy and recognise other planned improvements. We found the knowledge and experience of the representatives interviewed during the inspection to be good.
NNB have improvement plans in this area. The sustainability for these improvements can only be demonstrated following successful implementation and effective deployment. Therefore, ONR sampled the current HPC project records. We found the following:
ONR welcomes the consolidation of NNB’s records improvements under a single plan and leader. NNB described specific good practices for partitioning and development of a Lifetime Quality Record Strategy. Also Balfour Beatty and Socea-Denys have deployed adequate arrangements. Overall, ONR takes confidence from the dedication and commitment of these key individuals.
However, we found that Bylor’s delivery of records was not acceptable. Bylor are behind plan due to insufficient resources and therefore could not provide us with completed records to sample for some of the selected areas. Furthermore, NNB do not appear to have adequately communicated their records requirements to Bylor. As Bylor are carrying out the highest nuclear safety significant work at HPC we judge that NNB’s LC 6 arrangements are not adequate.
Despite focussed attention of LC6 arrangements by NNB, the implementation and deployment of the required improvements is behind plan.
ONR have assigned a rating of AMBER, seek improvement for this intervention.
ONR will consider a proportionate regulatory response to this and other similar findings in this area.