Office for Nuclear Regulation

LC19 Construction Surveillance intervention and Covid 19 control measures compliance intervention

Executive summary

Purpose of Intervention

In accordance with the Office for Nuclear Regulation’s (ONR’s) Hinkley Point C (HPC)  Construction Inspection Plan, ONR performs a series of planned compliance inspections of identified licence conditions (LC), to ensure that NNB Generation Company (HPC) Ltd (NNB GenCo), is proportionately and adequately developing and implementing its licence compliance arrangements commensurate to the current stage of the project.

In addition to a licence compliance inspection this intervention included a compliance inspection to assess the adequacy of NNB GenCo’s and its contractor’s Covid 19 control measures to ensure the health and safety of its employees in response to the Covid 19 pandemic.

Interventions Carried Out by ONR

LC 19 requires that “…the licensee shall make and implement adequate arrangements to control the construction or installation.”
The Health and Safety at Work etc Act 1974 (HSWA) requires that employers “ensure, so far as is reasonably practicable, the health, safety and welfare at work of all his employees.”

ONR carried out the following LC19; and HSWA Covid 19 control measures interventions:

The following guidance was used in this intervention:

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A as this was not a safety systems inspection.

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

LC19; Construction Surveillance

NNB GenCo is maintaining appropriate resources to deliver surveillance during the period of non-routine Covid 19 working including monitoring the availability of surveillance team members to ensure appropriate numbers of such staff are available.
NNB GenCo has in place comprehensive surveillance metrics to monitor and oversee the delivery of required surveillance.

ONR found that for sampled structures and components NNB GenCo was able to provide adequate evidence that required surveillance and quality records were in place to give confidence that they had been constructed / installed to design and quality requirements.

Adequacy of Covid 19 control measures

NNB GenCo and its contractors have put in place appropriate arrangements to manage the risk from Covid 19 in compliance with relevant industry guidance.

ONR observed effective implementation of Covid 19 control measures across the site and in areas of congested working including the heatsink (tunnel entrance) and nuclear island areas.

ONR observed that NNB GenCo should consider how it captures and shares good practices in relation to Covid 19 across the site, particularly for remobilising / new contractors.

Conclusion of Intervention

LC19; Construction Surveillance

Overall I judge that an inspection rating of GREEN (No formal action) is appropriate for LC 19; Construction or installation of new plant. This is because I am satisfied that NNB GenCo is implementing effective surveillance to ensure that plant is constructed / installed in accordance with its justified design and to required quality standards during the period of Covid 19 working.

Adequacy of Covid 19 control measures

Overall I judge that an inspection rating of Green (no formal action) is appropriate for Covid 19 (HSWA). This is because I found that NNB GenCo and its contractors were appropriately managing the risk from Covid 19 and were compliant with their legal duties.