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Routine LC28 intervention and site meetings including attendance at site stakeholder group

  • Site: Hinkley Point C
  • IR number: 19-022
  • Date: October 2019
  • LC numbers: 28

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 compliance arrangements commensurate to the current stage of the project.

This intervention included a routine licence condition inspection carried out to assess NNB GenCo (HPC)’s compliance with licence condition 28; Examination, inspection, maintenance and testing (EIMT)” assessing the adequacy and effectiveness of NNB’s implementation of its early preservation and maintenance activities.

In addition I held a number information sharing meetings and attended the HPC community forum.

Interventions Carried Out by ONR

LC28 requires that “The licensee shall make and implement adequate arrangements for the regular and systematic examination, inspection, maintenance and testing or plant which may affect safety.”

ONR carried out the following LC 28; Examination, inspection, maintenance and testing (EIMT) intervention:

  • A one day, routine licence compliance inspection against LC28 focusing adequacy and effectiveness of NNB’s implementation of its early preservation and maintenance activities.

The following guidance was used in this intervention:

  • NS-INSP-GD-019 Revision 5 “L19 – Construction or installation of new plant”
  • NS-INSP-GD-028 Revision 5 “LC28 Examination, inspection, maintenance and testing (EIMT)”

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

NNB has significantly improved the implementation of its care and maintenance requirements in its contracts.

NNB and its contractors were able to demonstrate that care and maintenance plans/activities are being implemented.

NNB has now developed an appropriate strategy for the production of care and maintenance technical standards and this has resulted in the production of relevant standards for current site activities.

There are now clear responsibilities in place for the development and implementation of care and maintenance requirements.
NNB has made sufficient progress for ONR to close its extant level regulatory issue which had required improvements to NNB’s preservation and maintenance arrangements during the construction phase.

Conclusion of Intervention

Overall I judge that an inspection rating of GREEN (No formal action) is appropriate for licence condition 28; Examination, inspection, maintenance and testing. This is because I have identified that NNB has developed and implemented appropriate arrangements for the preservation and maintenance of early construction activities. I do however note that further development will be required to ensure that the arrangements mature in line with project requirements.