- Site: Hinkley Point C
- IR number: 21-006
- Date: May 2021
- LC numbers: 17
Executive summary
Purpose of Intervention
The purpose of this intervention was to assess whether NNB Generation Company (HPC) Ltd, hereafter referred to as NNB GenCo (HPC), has defined, communicated, and subsequently assured implementation of its nuclear safety culture expectations to the Mechanical, Electrical and Heating, Ventilation and Air Conditioning Alliance (MEHA). This is important as MEHA plans to significantly increase its resources and presence on the Hinkley Point C construction site in the near future.
This intervention was undertaken as part of the Office for Nuclear Regulation (ONR) intervention plan, HPC Project Intervention Plan beyond J0.
Interventions Carried Out by ONR
Licence Condition 17 (Management Systems) requires NNB GenCo (HPC) to establish and implement management systems which give due priority to safety. As part of these nuclear safety prioritised management systems ONR expects NNB GenCo (HPC) to ‘make and implement adequate quality management arrangements in respect of all matters which may affect safety’.
I conducted this intervention remotely by interaction with NNB GenCo (HPC)’s and MEHA’s staff and documentation review.
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
I found that NNB GenCo (HPC) identified and specified in its contracts the expectations for nuclear safety culture development in MEHA and that a clear interface has been established. There is a good collaboration and level of engagement between NNB GenCo (HPC) and MEHA that now operates as a truly integrated alliance.
MEHA is fully adopting NNB GenCo (HPC)’s values and behaviours including nuclear safety culture training.
A suitable nuclear safety culture policy is in place.
A nuclear safety culture management plan describes key elements on the MEHA nuclear safety culture programme that includes Non-Conforming, Counterfeit, Fraudulent and Suspect Items (NCFSI) prevention measures. However, MEHA would benefit from a short, periodically reviewed document that declares short, mid-term, and long-term strategic goals for nuclear safety culture development.
I found MEHA nuclear safety culture team competent, committed, and sufficiently resourced.
A nuclear safety champions network has been established within MEHA to further promote nuclear safety culture.
MEHA nuclear safety culture arrangements seem to be appropriate for the current phase of the project.
MEHA provided examples how safety culture expectations are clearly communicated to its supporting suppliers.
I concluded from the interviews that MEHA leadership is committed, visible, and is reinforcing right message and integrated way of working.
MEHA takes part in regular nuclear safety culture survey, however some key performance indicators are still under development.
I identified the following two risks to further nuclear safety culture development that MEHA is cognizant of: anticipated significant growth of MEHA organisation and signs of personnel overload that might impact sustainability.
Conclusion of Intervention
Overall, based upon the judgements described above, I have concluded that an inspection rating of GREEN is appropriate for Licence Condition 17 – Management systems.