Executive summary
Date(s) of inspection
- December 2025
Aim of inspection
- To sample implementation of licensee's Pressure Systems Safety Case Policy (PSCP) for a specific system, structure or component (SSC).
- Gain confidence in licensee's arrangements to ensure compliance.
- Specifically sample the activities undertaken by the licensee's External Inspection Agency (EIA) in demonstrating compliance.
Subject(s) of inspection
- Health & Safety at Work Act - Rating: GREEN
Key findings, inspector's opinions and reasons for judgement made
The licensee, HPC, manages its entire scope of pressurised components under the auspices of its Nuclear Pressure Equipment (NPE) Policy (2020/304219) and the Pressure Systems Safety Regulations – Safety Case Policy (PSCP) (ONRW-932509302-23049). It has developed these policies over the last decade incorporating the essential safety requirements (ESRs) from the European Pressure Equipment Directive (PED) (Directive - 2014/68 - EN - EUR-Lex) and the “nuclear” specific French Regulations (ESPN Orders) to build the overall conformity process for the Hinkley Point C (HPC) site. The licensee has used those requirements as the foundational basis to demonstrate safety and conformity. Using those policies, it has taken an all encompassing approach to cover all types of safety (nuclear and conventional) significant pressurised components for HPC.
Considering the immensity and complexity of the HPC pressure systems scope, I had undertaken a series of interventions on the topic over last few years and this is the final part where I have considered the implementation of the PSCP requirements related to onsite installation activities and check those via sampling a number of installed components. I have particularly focussed on the licensee’s delivery of arrangements through the implementation of the conformity assessment process specifically targeting on-site surveillance activities.
Building on the past interventions on the topic, during the intervention, inter alia, I sampled the documentary evidence, held discussions with the appropriate stakeholders of the conformity process, checked and confirmed the supporting information and data on the licensee’s information management system, viewed installed components and used that information to trace the part of the conformity process that underpinned their installation.
Based on the evidence, discussions held and information gathered, for the scope of the intervention, I could clearly see the “golden thread” from receiving the components on-site from the manufactures to the point of their installation. I have concluded that the licensee has demonstrably followed the relevant PSCP requirements and has therefore complied with the conformity process. I have some follow-on activities, which I will manage via my routine regulatory engagements with the licensee.
Consequently, I have given a GREEN rating with no residual formal action or regularity issue raised.
Conclusion
Based on the evidence sampled and the discussions held with relevant stakeholders of the PSCP process, I am content that
- The licensee has been able to provide evidence of traceability from receipt of the components to installation for the sampled components
- The licensee’s surveillance arrangements are adequate to demonstrate that the installation related activities are demonstrably substantiated against the PSCP requirements
- The licensee has arrangements to control specialist activities like welding, non-destructive testing (NDT) etc. that are robust and meets the PSCP requirements
- The licensee has demonstrated its arrangements to deal with any non-conformance during installation to justify compliance with the PSCP requirements
- The licensee has demonstrated the “golden thread” for all the installation related activities to comply with the PSCP requirements.