Office for Nuclear Regulation

Remote inspection via Teams, Preparations for non-live Licence Conditions (DEV 4 Topic Stream)

Executive summary

Purpose of Intervention

The intervention examined the plans and strategy for future compliance with the relevant aspects of various non-live licence conditions (LC): LC 23: operating rules; LC 24: operating instructions; LC 25: operational records; LC 26: control and supervision of operations; LC 27: safety mechanisms, devices and circuits; LC 29: duty to carry out tests, inspections and examinations and LC 30: periodic shutdown.  My intervention focused on the progress of the developing plans and strategy for future compliance and benchmarked this against the current stage of the Hinkley Point C (HPC) project, recognising that the station is not yet in operation.

The intervention aimed to gain confidence in the implementation of NNB Generation Company (HPC) Limited’s (NNB GenCo) strategy for future compliance with the non-live licence conditions.  It also aimed to review NNB GenCo’s pre-operation’s readiness to perform its cross-functional duties in the future stages of the HPC project and ensure safe and reliable plant operations.

Interventions Carried Out by ONR

This planned intervention was conducted jointly with NNB GenCo’s internal regulator. 

The intervention included a programme of meetings to assess whether the licensee had developed key aspects associated with the progress towards an adequate strategy and implementation plan for non-live licence conditions.

The following guidance was utilised:

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable.

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

Although the Pre-Operations arrangements for Licence Conditions 23-27 and 29-30 will not be required for a number of years, it is important that a strategic road map and plans for the adoption of the licence conditions is in place now to aid the appropriate development of these arrangements in line with project milestones.

This intervention identified that there was insufficient development of the licence conditions adoption strategy.  There was limited consideration of developing an adequate overarching strategy that would then underpin a detailed delivery structure.

This intervention also identified no evidence of a specific forward work plan for the development and adoption of the arrangements for the non-live licence conditions to enable the tracking of the progress and clearly define the roles and responsibilities of individuals.  The clear understanding of forward work plans is key to ensuring effective links between all licence conditions, and that they have been identified and appropriately incorporated into the adoption strategy.

Conclusion of Intervention

I judge that for this stage of the HPC project, an overall inspection rating of AMBER is appropriate.  I consider that there was insufficient evidence of planning and developing arrangements for future compliance with the non-live licence conditions and that there was insufficient evidence of preparation for the transition to the next stage of the project. 

A regulatory issue will be raised to capture these areas for improvement.