- Site: Hinkley Point C
- Inspection ID: 51698
- Date: August 2022
- LC numbers: 17
Purpose of inspection
The purpose of this intervention was to assess the progress of NNB Generation Company (HPC) Limited’s (NNB GenCo (HPC)) planned improvements to the integrated management system (IMS).
The intervention related to licence condition 17 which requires a licensee to make and implement a management system that gives due priority to safety.
Subjects(s) of inspection
Licence Condition 17 – Management systems (Rating – Amber)
There is clear evidence of improvements to the IMS system being delivered and further improvements are being planned.
ONR observed that NNB GenCo (HPC) is effectively engaging with NNB GenCo (SZC) to share learning and collaborate on the development of the IMS.
From the information sampled, ONR identified that the management system manual (MSM) is currently circa 18 months beyond its planned review date, thus undermining the value of thedocument.
In addition to the MSM being beyond its review date, a significant amount of supporting documents to IMS procedures are also beyond their review date, which may result in a misalignmentbetween procedures and their supporting documentation.
ONR noted that activities in support of the mechanical, electrical, and heating, ventilation and air-conditioning (MEH) / design, install, manufacture and commission (DIMC) transformation project appear to be well structured, planned and controlled, with evidence of delivery.
In a number of instances, actions arising from IMS and/or management reviews were overdue and assigned to staff no longer in post.
ONR recommended that it may be beneficial in future management reviews to consider the effectiveness of key governance forums, for example the Management Systems Governance Group (MSGG).
In a number of instances dates were specified for activities that were late or appeared optimistic and it was not apparent whether there was any active prioritisation in terms of nuclear safety.
Overall, ONR concluded that an inspection rating of AMBER, seek improvement, is appropriate. A number of areas of good practice were highlighted, but improvement is required against specific areas. A regulatory issue has been raised to track NNB GenCo (HPC)’s resolution of the identified shortfalls.
The key area of improvement related to the overdue status of the management system manual and a significant amount of IMS supporting procedures. Moreover, this also calls into question the effectiveness of key governance forums and the overarching culture to implement adequate management system arrangements.