- Site: Hinkley Point C
- IR number: 22-009
- Date: June 2022
- LC numbers: N/A
Purpose of Intervention
The focus of the intervention was to sample the foreign materials exclusion (FME) processes produced by the licensee, how these are cascaded to the tier 1 contractors and there on to the sub-contractors. The intervention also sampled the application of these processes on site, the general condition of FME on site and how the operatives are engaging with and applying FME practices.
Interventions Carried Out by ONR
The following activities were carried out by ONR during the intervention:
- assess the development of management system arrangements in relation to FME; and
- assess the implementation of process and procedure governance arrangements.
I examined whether the licensee was aware of the relevant international guidance, with emphasis on the prevention, protection, exclusion and mitigation processes, particularly during planning and executing activities. Also, I examined whether these expectations were adequately translated into the local working documents for the licensee and its subcontractors.
As part of the intervention, the inspection team conducted a plant walkdown to review adequacy of implementation of arrangements in relation to these identified focus areas.
Explanation of Judgement if Safety System Not Judged to be Adequate
Key Findings, Inspector’s Opinions and Reasons for Judgements Made
The processes and controls for the exclusion of foreign materials on site were presented in a cogent and coherent manner and the licensee was able to describe how these are being cascaded down to its supply chain. Discussions with the licensee’s contractors and subcontractors sampled within the intervention showed that these parties had an adequate understanding of the reasons for and importance of foreign materials exclusion and also how the requirements and arrangements are to be exercised on site. It was not clear that the processes and procedures would be scalable up to a higher level of demand when installation rates increase, but the licensee demonstrated that plans and programmes to improve this within a timely fashion are in place and being progressed.
The site walk-down sampled areas where installation of plant was underway and where components were laid up prior to installation. No areas of concern were identified, housekeeping standards were to an appropriate level and staff encountered on the walk-down demonstrated adequate understanding of the need for good foreign materials exclusion. I judge that the systems and processes used were sufficient for the current status of construction and installation activities.
Conclusion of Intervention
For the areas sampled, the licensee presented adequate processes and procedures for the management of foreign materials exclusion on the HPC site. The contractors sampled in this intervention showed adequate understanding of the need for foreign materials exclusion and had implemented suitable measures for the current status of installation and construction activities at HPC.
Overall, based on the evidence observed, I judge that an inspection rating of Green (No Formal Action) is appropriate for this intervention. I will continue to monitor progress and adequacy of these matters through routine level 4 interactions.