- Site: Hinkley Point C
- Inspection ID: 51906
- Date: September 2022
- LC numbers: 12, 14, 17
Executive summary
Purpose of inspection
The aim of the inspection was to gather sufficient evidence of the selection and implementation of SMARTinstrument independent confidence building measures (ICBMs) to form a judgement as to whether they will provide proportionate confidence in the final design.
As described in the Office for Nuclear Regulation (ONR) safety assessment principle (SAP) ESS.27, standards and practices that the licensee apply should demonstrate 'production excellence' and the application of 'confidence-building' measures to provide proportionate confidence in the final design.
The objective was to undertake an inspection examining the people, process and product for selection and implementation of SMART instrument ICBMs.
ONR control and instrumentation (C&I) specialist inspectors undertook the intervention, on a sampling basis, to form a judgement on the adequacy of the arrangements associated with identification and selection of ICBMs. This was followed by sampling the implementation of those arrangements examining a class 1 (highest safety significance) SMART device and the competence of those individuals undertaking work which may impact safety ensuring they are suitably qualified and experienced persons (SQEP).
Subjects(s) of inspection
- Licence Condition 12 - Duly authorised and other suitably qualified and experienced persons (Rating Green)
- Licence Condition 17 - Management systems (Rating Green)
Key findings
Based on the evidence presented, areas of good practice relate to the people, processes, product with regard to identification and selection of smart device ICBMs, notably:
- personnel performing duties which may affect safety are SQEP;
- the licensee has produced specific guidance that should allow for a consistent identification and selection of ICBMs appropriate to the safety classification of the smart device; and
- the licensee has implemented its arrangements to enable the production and assessment of the Hinkley Point C (HPC) safety case.
I found two minor shortfalls:
- the overall justification that the ICBM selection (including justifying non-selection) is key to the overall demonstration that risks have been reduced as low as reasonably practicable (ALARP). It is not clear from examining the guidance as to where this justification will reside within the document structure and whether it will consist as a single justification of multiple justifications and an associated summary; and
- based upon my sampling, the licensee has satisfactory evidence to deliver an adequate safety case. However, the minor shortfall requires improvement in the presentation of that evidence so that an adequate SMART device ICBM selection justification can be provided to support the demonstration that risks have been reduced ALARP.
Judgement made
I judge that an intervention rating of GREEN (no formal action) is appropriate for licence condition (LC) 12 (duly authorised and other suitably qualified and experienced persons), LC17 (management systems) and LC14 (safety documentation).
LC12 – I found adequate arrangements in place which had been implemented to ensure that only suitably qualified and experienced persons (SQEP) are performing duties which may affect safety. This relates to the identification, selection and oversight of SMART device ICBMs.
LC17 – I found that the licensee has produced the elements in specific guidance that could allow for a consistent identification and selection of ICBMs appropriate to the class of the SMART device. Overall, I find this guidance to be adequate with the following minor shortfall:
- the overall justification that the ICBM selection (including justifying non-selection) is key to the overall demonstration that risks have been reduced ALARP. It is not clear from examining the guidance as to where this justification will reside within the document structure and whether it will consist as a single justification of multiple justifications and an associated summary.
LC14 – I consider that the licensee has implemented its arrangements to enable the production and assessment of the HPC safety case. From my sampling, I judge that the licensee has satisfactory evidence to deliver an adequate safety case but have highlighted the minor shortfall in the presentation of that evidence so that an adequate SMARTdevice ICBM selection justification can be provided to support the demonstration that risks have been reduced ALARP.
To record and track resolution of the two minor shortfalls I have raised a level 4 regulatory issue (RI-11063).