- Site: Hinkley Point C
- IR number: 21-001
- Date: April 2021
- LC numbers: 17
Executive summary
Purpose of Intervention
This intervention was conducted remotely with staff from NNB Generation Company (HPC) Ltd (hereafter referred to as NNB GenCo). It was undertaken as part of the ONR intervention plan, HPC Project Intervention Plan beyond J0.
Interventions Carried Out by ONR
I conducted a Licence Condition (LC) 17 (Management Systems) compliance inspection targeted on the Independent Nuclear Assurance (INA) System Lifecycle Assurance activity undertaken by Independent Technical Assessment (ITA). The objectives of this intervention were to:
- gain confidence in INA’s ability to plan, organise and manage interventions;
- observe how INA interacts with the licensee and others, and influences improvements to nuclear safety;
- assure the adequacy of system lifecycle assurance work; and
- understand preliminary findings from the system lifecycle assurance work.
ITA shared its approach for System Lifecycle Assurance at an initial intervention conducted in December 2019. In this intervention I assessed NNB GenCo’s LC arrangements and implementation of those arrangements against relevant good practice, which included the following ONR regulatory guidance:
- Nuclear Safety Technical Inspection Guide, LC 17 Management Systems, NS-INSP-GD-017
- Nuclear Safety Technical Assessment Guide, Challenge Culture, Independent Challenge Capability (including an Internal Regulation function), and the provision of Nuclear Safety Advice, NS-TAST-GD-080
Key Findings, Inspector's Opinions and Reasons for Judgements Made
I found that NNB GenCo ITA activities in relation to the System Life Cycle Assurance work were appropriately planned and targeted and that the resulting assessment reports were well founded and clearly identified relevant issues. Findings are collated into summary reports that are given sufficient prominence within the licensee organisation (including presentation at the company board and at Nuclear Safety Committee), resulting in actions being implemented to influence improved safety outcomes. Through review of relevant minutes and discussion with senior internal stakeholders I concluded that the work of the INA function is well respected and considered to be effective. I also found that when actions are formally placed there is a robust process for tracking to completion.
During my inspection I raised a number of observations for the licensee to consider to make the work of ITA more effective. These observations primarily related to categorisation and transparency of findings and effectiveness review of actions post implementation.
I judged that, on the evidence sampled, NNB GenCo has adequately implemented arrangements for INA, consistent with relevant good practice as defined in ONR regulatory guidance.
Conclusion of Intervention
Overall, based upon the judgements described above, I have concluded that an inspection rating of ‘GREEN’ is appropriate for LC17 Management Systems.