- Site: Hinkley Point C
- IR number: 20-015
- Date: October 2020
- LC numbers: 19
Executive summary
Purpose of Intervention
In accordance with the Office for Nuclear Regulation (ONR) Hinkley Point C Construction Inspection Plan, ONR performs a series of planned compliance inspections of identified licence conditions. This is to ensure that the licensee, NNB Generation Company (HPC) Ltd (NNB GenCo), is adequately developing and implementing its licence condition compliance arrangements in a manner commensurate with the stage of the project under consideration.
This intervention was an inspection carried out to assess the licensee’s compliance with licence condition 19 (LC19) Construction or Installation of New Plant. LC19 requires that where the licensee proposes to construct or install any new plant, which may affect safety, the licensee makes and implements adequate arrangements to control the construction or installation.
This intervention was led by ONR civil engineering construction assurance (CECA) and sought to assess the licensee’s application of relevant good practice (RGP) in the area of ensuring compliance with the construction specification for the nuclear island structures of Unit 2.
Intervention Aims
The intervention was a formally rated intervention done principally against the requirements of LC19. This was a joint intervention conducted with NNB GenCo’s Independent Nuclear Assurance (INA). INA reviewed and contributed to the scope. This intervention record records ONR’s areas of interest and findings. INA will produce a separate report covering its own particular areas of interest and findings.
The principal aims of the intervention can be summarised as follows:
- To derive confidence that significant risks of technical non-conformance in construction are understood and are being appropriately controlled.
- To gain an understanding of the state of planning and arrangements for implementation of the works in question; including an understanding of the basic structure of the works information pertaining to this activity.
- To derive confidence that RGP is in place with respect to civil engineering construction practice.
Explanation of Judgement if Safety System Not Judged to be Adequate
This section is not applicable as this was not a safety system inspection.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
The intervention was well managed and NNB GenCo planned for attendance by the appropriate personnel. The evidence submitted was of good quality and submitted in a timely fashion that has allowed me to form a regulatory judgement.
Overall, I was satisfied with the licensee’s current arrangements to assure conformant construction of the Unit 2 civil engineering works. This topic is one of continued regulatory interest and it is acknowledged that significant challenges exist in establishing and implementing practical arrangements to assure conformant construction on any major civil engineering site; particularly where multiple contractual interfaces exist and where design release is overlapping with construction. To this end, my regulatory interest in this topic will continue beyond this intervention.
Several actions were agreed from this intervention, which will be followed-up through the future regular interactions with the licensee. The actions do not affect my assessment rating.
Conclusion of Intervention
Based on the evidence sampled I was satisfied that the licensee’s arrangements met relevant good practice. I therefore judge that a rating of GREEN (No formal action) is appropriate against this LC19 intervention.