Office for Nuclear Regulation

Implementation of the Competence Management arrangements for Future Operators and Maintainers

Executive summary

Purpose of Intervention

This intervention was undertaken on 20th to 21st January 2020 at NNB GenCo’s (NNB) Cannington Court in Somerset.

The inspection examined compliance with the relevant aspects of Licence Condition (LC) 10 (Training) and LC12 (SQEPs/DAPs) as appropriate to the current stage of the Hinkley Point C (HPC) project and recognising that the station is not yet in operation.

The inspection aimed to gain confidence that the implementation of NNB’s competence management arrangements specifically for station operators and maintainers are sufficiently progressed for this stage of the lifecycle and that there was evidence of sufficient preparation for the transition to the next stage.

This intervention is one of a number of interventions in the area of Competency Management defined in the ONR HPC Intervention Plan (CM9 2019/95951). Early inspections of this nature are an important element of ONR’s activities to gain confidence that the pre-operations competence management arrangements are sufficiently well developed.

This intervention should be used as a benchmark for further interventions to monitor progress in relation to competence management and training development for future operators and maintainers. It is recommended that a further inspection against NSTAST-GD-027 - Training and Assuring Personal Competence is conducted to consider the maturity of the arrangements for operators and maintainers no later than January 2021.

Interventions Carried Out by ONR

This planned compliance inspection was undertaken against the relevant aspects of
the following (given the current stage of the HPC project):

The inspection included a programme of meetings to assess whether the Licensee is developing suitable arrangements with regard to training for those staff who roles may affect safety.

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A. A system inspection was not undertaken.

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

NNB has put in place new arrangements for competence management for future operators and maintainers, based mainly on those in NGL following the forming of much closer links between NNB and NGL. I consider these processes and systems to be aligned with UK requirements and take confidence from the fact that NNB is now adopting arrangements that have previously been considered to be in line with RGP by ONR.

NNB is developing its training programmes through the System Approach to Training (SAT) process. SAT is recognised by ONR as a suitable process that can be used to provide suitable training for those who have responsibility for operations which may affect safety.

I also noted the pragmatic approach that has been taken to utilising existing documentation within NGL as input to the process including role profiles/competencies and training programmes where appropriate. Although limited material was available for examination, I considered the material to be of an adequate standard.

I consider the organisation structure in place and organisation of the work to be appropriate to deliver to the plan. Three main programmes of work have been identified and three direct reports to the Deputy Pre-Operations Director are each responsible for one of the three main work programmes.

Whilst noting evidence of a credible training/competence management development plan with an associated resourcing plan, I consider the timescales to be challenging.

Although the plan demonstrated that meeting the timescales was achievable, I did identify a number of risks to achieving this plan such as availability of a fully representative simulator. At this stage of the project I took confidence from NNB being aware of these risks and being in the process of addressing them with appropriate mitigation.

Governance arrangements have been put in place to oversee progress including a three-tiered Competency Committee Structure. Although NNB is at the early stage of implementation of the committee structure, the arrangements seem workable and appropriate to their requirements.

Conclusion of Intervention

I judge that for this stage of the HPC project, an overall an inspection rating of Green (adequate) is appropriate. I considered that there was evidence of sufficient progress in the implementation of the arrangements for this stage of the lifecycle and that there was evidence of sufficient preparation for the transition to the next stage.