Office for Nuclear Regulation

LC06 and COVID-19 intervention August visit

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 and in accordance with evolving government guidance.

In addition I carried a number of additional information sharing discussions. This included a visit to the area of the Ground Granulated Blast Furnace Slag (GGBS) silo area where I was provided with an update on the status of NNB GenCo’s and its main civil works contractor Bylor’s investigation into the structural collapse of the non-nuclear safety related GGBS silo which occurred in June 2020.

Interventions Carried Out by ONR

LC 06 requires that “…the licensee shall make adequate records to demonstrate compliance with any of the conditions attached to this licence.”

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 LC06; 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

LC06; Lifetime Quality Records

ONR identified that the records as presented for one of the sampled items, the core melt discharge channel did not yet fully demonstrate compliance with expected lifetime quality record requirements.

ONR found that the site records for reinforced concrete are being produced to a high standard.

It was evident that NNB and its contractor’s improvement activities for the production of LTQRs has not yet been fully effective as overall LTQR delivery was not yet in accordance with project requirements. This is not wholly unexpected as NNB’s improvement plan in this area is still in the process of implementation and its effectiveness in securing the required improvements will monitored as part of ongoing regulatory engagement on this matter.

Adequacy of Covid 19 control measures

NNB and its contractor’s arrangements to manage the risk from Covid 19 have evolved to ensure compliance with revised government and industry guidance.

ONR noted a potential small increase in instances where workers were inadvertently breaching social distancing requirements although it was evident that appropriate coaching was taking place to address these isolated lapses.

Whilst the control of Covid 19 risk remains adequate at site, continued focus and effort will be required to ensure that the site is prepared to manage Covid 19 risks across the potentially more challenging winter period.

Conclusion of Intervention

LC6; Lifetime Quality Records

Overall I judge that an inspection rating of AMBER (Seek improvement) is appropriate for LC 06; Documents, records, authorities and certificates. This is because I found that there had been delays in producing required lifetime quality records for a number of items such that they did not yet meet NNB’s timescales for delivery. Furthermore I considered the as presented records for one of the sample components - the core melt discharge channel did not appear to fully meet expected requirements.

Given that ONR has an extant level 2 regulatory issue regarding LTQR delivery and is monitoring NNB’s delivery against the associated improvement plan I do not consider that an additional regulatory issue is required on this matter. However I have raised a new level 3 regulatory issue requiring NNB to review the adequacy of the records associated with the core melt discharge channel (and associated components).

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.