Office for Nuclear Regulation

HPC - Inspection of the NCSS validation and EMC testing - Intervention Record

Executive summary

Purpose of Intervention

The purpose of the intervention was to gain confidence in the adequacy of NNB Generation Company (HPC) Limited’s (NNB GenCo) arrangements, and those of its supporting organisations, covering the factory acceptance (validation) and electromagnetic compatibility (EMC) testing of the non-computerised safety system (NCSS) and supporting safety case.

Interventions Carried Out by ONR

Office for Nuclear Regulation (ONR) control and instrumentation (C&I) specialist inspectors undertook a remote intervention (via videoconference) to form a judgement on the adequacy of the arrangements associated with validation and EMC testing of the NCSS and supporting safety case for Hinkley Point C (HPC).

ONR technical assessment guides NS-TAST-GD-051 (The purpose, scope, and content of safety cases), NS-TAST-GD-049 (Licensee Core Safety and Intelligent Customer (IC) Capabilities) and expectations for compliance with Licence Condition (LC) 12 (Duly authorised and other suitably qualified and experienced persons), LC 14 (Safety documentation) and  LC 17 (Management systems) were used to inform ONR’s judgement during this intervention.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable as this was not a system/structure-based inspection.

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

Based on the evidence presented, areas of good practice relate to the procedures for specifying required quality, scoping and implementation of testing, demonstrating that adequate arrangements are in place:

I found areas of improvement relating to non-conformance management and verification activities which I have raised as observations and I consider can be pursued through regular level 4 meetings with the licensee.

Conclusion of Intervention

I judge that an intervention rating of GREEN (no formal action) is appropriate for LC 12 (Duly authorised and other suitably qualified and experienced persons), LC 14 (Safety documentation) and LC 17 (Management systems).

LC12 – I found the arrangements in place adequate to ensure that only suitably qualified and experienced persons are performing duties which may impact safety (in this case the testing of the NCSS).

LC14 – I consider the arrangements sampled provide confidence that the safety requirements are adequately translated into the scope of testing, the results of the testing are adequately assessed and the licensee maintains satisfactory oversight over the testing, delivering its intelligent customer role. The project maintains adequate arrangements for raising, assessing and addressing non-conformances.

LC17 – I found the quality arrangements in place adequate, which have been satisfactorily implemented for the specification, testing (validation and EMC) and assessment of the NCSS.