- Site: Hinkley Point C
- IR number: 21-011
- Date: July 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 put in place and implemented suitable arrangements to mitigate potential safety and quality issues arising from multiple languages and cultures at Hinkley Point C (HPC) site.
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 documentation review and by interaction with staff from NNB GenCo (HPC), BYLOR and Tissot, Balfour Beatty, and the Mechanical, Electrical and Heating, Ventilation and Air Conditioning Alliance (MEHA).
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) acknowledges the risk stemming from multiple languages and cultures on the site and has put in place written expectations to address it.
NNB GenCo (HPC) and its contractors provided satisfactory examples of the implementation of these expectations, such as extensive use of visual management, clarification of documents, use of translators, sharing of good practice, monitoring of numbers of non-English speaking workers, considering future profile of the personnel on site, and focusing on inclusion in general.
NNB GenCo (HPC) monitors this area using recorded observations on site, industrial safety reports, and independent nuclear assurance assessments.
Based on the meetings observed, I was satisfied with the leadership support for the topic of clear communication and nuclear safety culture in general.
However, I found a gap in setting a clear expectation for the appropriate ratio of English speaking supervisors to non-English speaking workers, for which I raised a regulatory issue.
Conclusion of Intervention
Overall, based upon the judgements described above, I have concluded that notwithstanding a minor shortfall, that will be follow-up with a level 4 (lowest significance) regulatory issue, an inspection rating of GREEN is appropriate for Licence Condition 17 – Management systems.