- Site: Hinkley Point C
- IR number: 20-029
- Date: February 2021
- LC numbers: 19
Executive summary
Purpose of Intervention
In accordance with the Office for Nuclear Regulation (ONR) Hinkley Point C (HPC) Construction Intervention 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.
The purpose of this intervention was to assess the role of the NNB GenCo Joint Design Office (JDO) to deliver its functions with respect to Civil Engineering.
Interventions Carried Out by ONR
This intervention was 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.
ONR carried out a remote intervention over two days. The objectives of which can be summarised as follows:
- examine the functions being delivered by the JDO;
- understand arrangements and processes developed to deliver these functions;
- ensure adequacy of arrangements and processes developed to deliver these functions; and
- assess production of a specific work package which has been developed into Unit 2 deliverables.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
The update provided by NNB GenCo on the JDO organisation update was clear. ONR was reassured to see challenges being pre-empted several years prior to the anticipated project need. ONR noted that the design capability provided to site by the JDO is not completely novel and was previously undertaken by the Site Engineering Team (SET) and Site Design Liaison Team (SDLT), which have been replaced by JDO.
The new JDO Task Force role appeared to be an effective means of dealing with emergent issues on site and ONR was reassured that that established processes are not being circumvented to expedite issues. ONR noted that the Task Force was resource intensive but existing flexibility within the JDO structure allowed quick redeployment of resources. Whilst ONR remained unclear on the specific circumstances which led to the formation of a Task Force, ONR noted that the Terms of Reference under development would provide greater clarity, particularly with the upcoming increased complexity from additional interfaces during mechanical, electrical and heating, ventilation and cooling (MEH) installation.
The JDO ‘review and acceptance’ intelligent customer role appeared to be similar to that undertaken previously by SET.
ONR welcomed development of additional guidance to clarify the roles and responsibilities of the various internal JDO teams.
The development of quality arrangements appears to be forward-thinking and aimed at addressing upcoming challenges to the MEH programme. ONR noted that it was positive to see JDO taking ownership of its management systems and quality arrangements by establishing a single Integrated Management System (IMS).
The Unit 2 replication strategy was clear and sets high level principles for the HPC project to achieve. However, ONR noted that there appears to be little guidance on how this strategy should be implemented at a working level. ONR recognised that guidance was under development but reiterated that HPC was an established project, with significant ongoing Civil Engineering work.
It was established that configuration control was maintained using the COMET tool whilst drawings were stored in Teamcenter. However, ONR noted that due to the lack of available guidance there appeared to be inconsistent controls applied to various work packages. Whilst ONR recognised the need for striking a balance between project agility and prescriptive processes, JDO would benefit from a systematic approach to configuration control.
Conclusion of Intervention
On the basis of the evidence gathered during this inspection, I judge that an inspection rating of GREEN, with no formal action, is appropriate against Licence Condition 19. This is because I found no significant shortfalls.