Office for Nuclear Regulation

Hinkley Point C LC17 intervention

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) and other applicable legislation, to ensure that NNB Generation Company (HPC) Ltd (NNB GenCo), is meeting its legal requirements.

Interventions Carried Out by ONR

Licence condition 17 requires that “the licensee make and implement adequate quality management arrangements in respect of all matters which may affect safety.”

ONR carried out the following LC17 intervention:

The following guidance was used in this intervention:

ONR carried out the following HSWA Covid 19 control measures 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

LC17 - Inner Containment Fabrication Quality Arrangements

NNB GenCo and its contractors were able to provide appropriate examples of quality issues being identified and improvements implemented to improve quality performance.

ONR found that the relevant main civils programme quality arrangements/documentation had not been fully implemented/reviewed.
ONR noted a number of instances where NNB GenCo’s quality requirements appeared to have not been fully implemented by NNB GenCo’s suppliers or as implemented they did not appear to align fully with NNB GenCo’s requirements.

Adequacy of Covid 19 control measures

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

ONR found that overall NNB GenCo and its contractors are continuing to appropriately manage the risk from Covid 19.

ONR did however identify a small number of relatively minor areas for potential further improvement and has provided appropriate advice to NNB GenCo on these matters.

Conclusion of Intervention

LC17 Implementation

Overall I judge that an inspection rating of AMBER (seek improvement) is appropriate for LC17; Management systems. I judge that NNB GenCo was not able to demonstrate that its quality management system and underpinning processes have been fully implemented in relation to the inner containment liner fabrication. As such I have raised a new level 3 regulatory issue to capture this matter. I note that ONR has an extant level 3 regulatory issue in relation to the implementation of NNB GenCo’s delivery programme quality management system arrangements and hence no new regulatory issue is required for this finding from the intervention.

Adequacy of Covid 19 control measures

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. I did however identify a small number of areas where NNB GenCo could potentially further improve and these relatively minor improvement areas have been communicated to the licensee.