Skip to content

NSC6 - Intervention on Learning and Improvement

  • Site: Hinkley Point C
  • IR number: 21-040
  • Date: February 2022
  • LC numbers: 7

Executive summary

Purpose of Intervention

The purpose of this intervention was to assess the effectiveness of NNB Generation Company (HPC) Limited (NNB GenCo)’s improvement plan implementation in returning it to compliance with Licence Condition (LC) 7 requirements.

Interventions Carried Out by ONR

LC 7 requires that “The licensee shall make and implement adequate arrangements for the notification, recording, investigation and reporting of such events occurring on the site”. ONR expects that lessons should be learned from internal and external sources to continually improve leadership, organisational capability, safety decision making and safety performance.

This intervention was conducted remotely by interaction with NNB GenCo’s staff, documentation review and observation of key meetings.

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 had improved its learning function in several areas as follows:

  • key performance indicators are now in place, and the data is widely accessible and provides good visibility of existing issues;
  • the new ‘Insight’ inspections module increases the ability to capture and analyse learning;
  • requests for learning and lessons learnt workshops are a significant improvement for the HPC project’s use of learning; and
  • use of external learning has further improved.

However, I identified shortfalls in the following areas:

  • delay of release 2 of the Insight learning tool;
  • limited use of Insight by the contract partners;
  • availability of up-to-date arrangements – this was directly related to the change in Integrated Management System at the time of the intervention;
  • investigation priority criteria are not clear in the current investigation procedure;
  • inconsistency of investigation reports with existing templates;
  • limited visibility of investigation reports in Insight;
  • management of competency and related low number of competent and trained investigators;
  • management of adverse trends; and
  • Corrective Action Review Group effectiveness.

Conclusion of Intervention

Overall, based upon the judgements described above, I have concluded that an inspection rating of AMBER is appropriate for Licence Condition 7 – Incidents on the site.

I raised a level 3 regulatory issue to capture the shortfalls identified during the intervention.