Office for Nuclear Regulation

QU3: NNB GenCo Integration, Oversight and Integrated Management System (IMS) arrangements

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, to ensure that NNB Generation Company (HPC) Ltd (NNB GenCo) is proportionately and adequately developing and implementing its licence condition compliance arrangements commensurate to the current stage of the project.

The purpose of this intervention was to gain confidence that NNB GenCo is adequately deploying the Integrated Management System (IMS) arrangements, with appropriate consideration of nuclear safety.

Interventions Carried Out by ONR

ONR conducted a Licence Condition (LC) 17 (Management Systems) compliance inspection targeted on the NNB GenCo quality management arrangements. This involved sampling the IMS Assurance, Audit and Self-assessment programmes to confirm they are adequately testing the IMS arrangements.

ONR assessed NNB GenCo’s LC arrangements against relevant good practice, which included ONR regulatory guidance, specifically relevant Technical Inspection Guides and Technical Assessment Guides.

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

Based on the discussions and evidence provided during Phase 1 and Phase 2 of the intervention, ONR concluded that the NNB GenCo IMS is well structured and represents a number of improvements identified in the NNB GenCo IMS Strategy paper (2019). However, it is acknowledged that NNB GenCo plans to implement further improvements during 2021.

ONR observed that NNB GenCo has developed and implemented an adequate approach to managing changes to IMS processes and procedures based on the nuclear safety importance and scale of change.

From the evidence sampled and discussions held, ONR observed that core IMS quality and project documents have not been consistently implemented and/or maintained across the HPC contracts and/or Programmes.

ONR noted that the delivery of NNB GenCo self-assessments were behind the baseline plan and would not be recovered during 2020. NNB GenCo has acknowledged the shortfalls, which mirrored those previously identified during an earlier intervention undertaken in October 2019. In order to provide greater focus and improve self-assessment performance and ensure it covers a review of safety leadership across all organisational levels and functions in the NNB GenCo / HPC organisation, NNB GenCo has agreed for the quality function to manage self-assessments from 2021.

From the records presented and sampled, ONR observed a lack of clarity in the internal reporting metrics and dashboard for: IMS audits, procedure application and future procedure development.

ONR noted the recruitment of a replacement IMS Manager and IMS resource as positive indicators and recognised that this should contribute to delivering the planned enhancements to the NNB GenCo IMS.

Conclusion of Intervention

Overall, ONR concluded that an inspection rating of AMBER, seek improvement, is appropriate. Areas of good practice were highlighted, and ONR acknowledges that further developments are planned. However, based on the selected samples examined, shortfalls were identified in the deployment and maintenance of the IMS arrangements.

An appropriate regulatory issue will be raised to address the shortfalls identified during this intervention.