- Site: Hinkley Point C
- IR number: 20-022
- Date: November 2020
- LC numbers: 19
Executive summary
Purpose of Intervention
Licence condition (LC) compliance interventions are an essential element of the Office for Nuclear Regulation’s (ONR's) overall intervention strategy which consists of a series of interventions. Each intervention is intended to establish that the licensee has adequate arrangements in place for compliance with a licence condition. Inter alia, LC 19 requires that:
Where the licensee proposes to construct or install any new plant which may affect safety the licensee shall make and implement adequate arrangements to control the construction or installation.'
The aim of this intervention was to gain confidence that the licensee had adequate arrangements in place for compliance with LC 19, in relation to manufacturing assurance in justifying the relevant pressure regulations compliance by implementing its nuclear pressure equipment and nuclear pressure systems policies across the supply chain. Moreover, the licensee had taken the role as the ‘manufacturer’ of nuclear pressure equipment and nuclear pressure systems and therefore had legal responsibility for the implementation of the conformity assessment process and demonstration of pressure regulation compliance. The intervention checked whether the licensee was undertaking that role effectively.
Interventions carried out by ONR
The intervention comprised a launch meeting, a review of documents and a meeting where the licensee explained the implementation of its arrangements for two items of nuclear pressure equipment and nuclear pressure systems, the main coolant pump (MCP) casing and the sump suction line (SSL).
Key findings, inspector’s opinions and reasons for judgments made
My key findings are that the licensee has demonstrated that:
- its policies and expectations for pressure regulations compliance were reasonably understood by the supply chain;
- where its supply chain did not meet its expectations, it could provide sufficient support to enable a contractor to address the shortfall; and
- for the MCP casing and SSL, the conformity assessment process and the safety requirements were adequately justified.
Therefore, I consider that the licensee can justify its role as ‘manufacturer’ through its arrangements for compliance with the relevant pressure regulations and implementation of its nuclear pressure equipment and nuclear pressure systems policies with its supply chain.
Conclusion of intervention
I conclude that the licensee has demonstrated adequate arrangements in place for compliance with LC 19, in relation to the manufacturing assurance of nuclear pressure equipment and nuclear pressure systems at HPC and for its role as ‘manufacturer’ of nuclear pressure equipment and nuclear pressure systems. An inspection rating of Green is appropriate for LC 19 (Construction or installation of new plant).