Executive summary
Date(s) of inspection: March 2024
Aim of inspection
The protection system (PS) V-1 functional testing is now underway at the Framatome TXS testbay facility in Erlangen, Germany. The PS is a class 1 safety system implementing category A nuclear safety functions. It is a large and complex software-based control and instrumentation system and testing plays a significant role in the safety justification. The PS V2 software is effectively the version of software for delivery to site. The inspection aimed to assess compliance with licence conditions (LC) 12, 14 and 17 and to sample evidence to support progress of regulatory issue RI-11405, relating to the use of the early involvement process (EIP) for managing test procedures. The overall aim of the inspection was to gain confidence in the arrangements and processes in place to support a successful functional testing campaign of the PS.
Subject(s) of inspection
- LC12 - Duly authorised and other suitably qualified and experienced persons - Rating: Green
- LC14 - Safety documentation - Rating: Green
- LC17 - Management systems - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
Based on the evidence sampled during this inspection against LCs 12, 17 and 14, I found the arrangements in place for functional testing (V-1) of the protection system version 2 to be appropriate and prerequisite activities adequately implemented. This provides confidence that the V-1 test results will be appropriately robust to support the overall safety justification for the Hinkley Point C (HPC) protection system.
The inspection reviewed processes and sampled records relating to test bay team personnel qualifications and experience, requirements traceability, test procedure preparation, the control of test bay test configuration, and test results. This sampling, and the associated discussions, provided confidence that the arrangements in place are comprehensive, robust, well understood and are being followed in practice. Throughout the inspection I observed a good level of knowledge from all staff involved.
I made observations under LC17 regarding minor improvements to the work instruction for the management of test procedures at the test bay, and improving traceability of verification comments raised and implemented in procedure revisions; this will be followed up via a new action under an existing regulatory issue (RI-11405). Although I am broadly content the current process is being implemented effectively during the preparation of test bay procedures, these improvements will result in a more robust process for traceability of the verification performed prior to the accepted versions of test procedures used for V-1 validation.
I informed the licensee, NNB Generation Company (HPC) Ltd, that I will look to review the test records produced after completion of V-1 testing.
The inspection reviewed processes and sampled records relating to test bay team personnel qualifications and experience, requirements traceability, test procedure preparation, the control of test bay test configuration, and test results. This sampling, and the associated discussions, provided confidence that the arrangements in place are comprehensive, robust, well understood and are being followed in practice. Throughout the inspection I observed a good level of knowledge from all staff involved.
I made observations under LC17 regarding minor improvements to the work instruction for the management of test procedures at the test bay, and improving traceability of verification comments raised and implemented in procedure revisions; this will be followed up via a new action under an existing regulatory issue (RI-11405). Although I am broadly content the current process is being implemented effectively during the preparation of test bay procedures, these improvements will result in a more robust process for traceability of the verification performed prior to the accepted versions of test procedures used for V-1 validation.
I informed the licensee, NNB Generation Company (HPC) Ltd, that I will look to review the test records produced after completion of V-1 testing.
Conclusion
I judge that an inspection rating of green (no formal action) is appropriate for LC12: duly authorised and other suitably qualified and experienced persons. I was content with Framatome’s own arrangements and the licensee’s oversight of these arrangements for assessing and demonstrating there are suitably qualified and experienced personnel.
I judge that an inspection rating of green (no formal action) is appropriate for LC17: management systems. The focus of the LC 17 aspects of the inspection was the Early Involvement Process (EIP) for control of test bay procedures. Although I made observations regarding updates to the work instruction, and improving traceability of comments against procedure versions, I was content that the EIP is well understood and is being correctly and robustly implemented during the preparation of test bay procedures and therefore consider that an overall rating of green is appropriate.
I judge that an inspection rating of green (no formal action) is appropriate for LC14: safety documentation. I consider the licensee has implemented adequate arrangements for the production and assessment of safety cases with specific regard to the testing of the HPC PS V2 at the test bay.
I judge that an inspection rating of green (no formal action) is appropriate for LC17: management systems. The focus of the LC 17 aspects of the inspection was the Early Involvement Process (EIP) for control of test bay procedures. Although I made observations regarding updates to the work instruction, and improving traceability of comments against procedure versions, I was content that the EIP is well understood and is being correctly and robustly implemented during the preparation of test bay procedures and therefore consider that an overall rating of green is appropriate.
I judge that an inspection rating of green (no formal action) is appropriate for LC14: safety documentation. I consider the licensee has implemented adequate arrangements for the production and assessment of safety cases with specific regard to the testing of the HPC PS V2 at the test bay.