Office for Nuclear Regulation

Management of NCR and FCR processes - CD4

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.

Interventions Carried Out by ONR

LC 19 requires that “the licensee shall make and implement adequate arrangements to control the construction or installation.”
ONR carried out the following LC19 intervention:

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

It is evident that NNB GenCo has developed and implemented comprehensive key performance indicators which facilitate appropriate oversight of the effectiveness of the FCR and NCR processes. 

Overall, it was evident that there had been an improvement in the recorded nuclear safety categorisations sampled, but opportunities for further refinement exist potentially aided by improved categorisation guidance/clarity on its application.

Whilst it is evident that NNB GenCo has mature FCR and NCR processes ONR considers that NNB GenCo should review whether further guidance is required regarding the application of the NCR and FCR processes to ensure consistency of application/content across the NCRs and FCRs raised by the various contractors working at the HPC site. 

The mechanical, electrical and heating, ventilation and air conditioning (MEH) alliance who will be fitting out the civil structures will need to ensure that it develops and deploys its integrated management arrangements for the management of both NCRs and FCRs prior to it commencing the more significant (whilst still relatively small scale) activities associated with the fit out the raw water supply and storage liaison gallery (HGE).

Conclusion of Intervention

Overall, I judge that an inspection rating of Green (no formal action) is appropriate for LC 19. This is because I found that NNB GenCo is compliant with its legal duties with only relatively minor areas for improvement being identified, the most important of which have been captured in an associated level 4 (the lowest level) regulatory issue.