Date(s) of inspection:
- October 2022
Aim of inspection
The purpose of this inspection was to seek confidence that NNB Generation Company (HPC) Ltd (NNB GenCo) has put in place and implemented suitable arrangements for driving safety and security culture across the organisation and cascaded the requirements into its workforce and key suppliers or contractors. The inspection focused on culture at Hinkley Point C (HPC) site from nuclear safety, nuclear site health and safety, and nuclear security points of view. In addition, an Environment Agency specialist was invited to consider environmental aspects for Environment Agency purposes.
This inspection was undertaken as part of the Office for Nuclear Regulation (ONR) inspection plan.
Subject(s) of inspection
- CDM 15 (Client / PD / PC duties) – Rating: Amber
- FSyP 2 – Organisational Culture – Rating: Green
- LC17 – Management systems – Rating: Green
- Overall Inspection Rating – Rating: Amber
Key findings, inspector’s opinions and reasons for judgement made
Nuclear Safety Culture
We found that NNB GenCo has put in place suitable arrangements for driving nuclear safety culture across the organisation. The expectations were clearly identified and specified in NNB GenCo’s contracts and were cascaded down the supply chain by the Tier 1 contractors on the HPC site. These requirements are understood and being implemented by the Tier 1 contractors that we sampled. NNB GenCo monitors and measures the fulfilment of these requirements. We found from the observations and focus group interviews that the site workers seem to understand and live the key HPC project values and ‘Right First Time’ approach.
We concluded that nuclear safety culture is being developed proportionately to the current risk on site.
We found that NNB GenCo has put in place suitable arrangements for driving security culture across the organisation. We observed some good practice in the review of each security awareness campaign. There appeared to be adequate human resource allocated to security culture at this time, with a member of staff responsible for culture, with support provided across the security function and beyond. There was a reasonable level of security understanding within the focus group membership.
We concluded that security culture is being developed proportionately to the current risk on site.
Nuclear Site Health and Safety Culture
We found that NNB GenCo has put in place arrangements for driving nuclear site health and safety culture across the organisation. The Principal Contractor standards are clearly identified and specified in NNB GenCo’s contracts. These are being monitored using Principal Contractor Monthly Standard Review and Principal Contractor Audit Schedule.
NNB GenCo uses a site-wide initiative, HPC Way, as its key initiative for the health, safety, environment, and sustainability culture. We observed several positive examples of communication of safety improvement initiatives such as HPC Values posters, HPC Way and Zero Harm Week across the HPC site.
However, our observations and focus group data indicated that the arrangements are not sufficiently implemented. We spoke with about 100 site personnel out of more than 9000 people who are on site every day. Though the sample is relatively small, aspects of the feedback was common across groups.
In particular, we found that the tool for reporting of site observations is not yet deployed as widely as it should be with operatives either not trained or without access to the tool. The workers that we interviewed often did not receive any feedback about the outcome of the observations they reported. Moreover, many construction workers did not feel sufficiently informed about site incidents, despite a recent information learning campaign, or about the outcome of these incidents. It was considered that some of the observations and feedback indicated a shortfall against Regulation 13 of The Construction (Design and Management) Regulations 2015 (CDM), which requires that the Principal Contractor has a duty to plan, manage and monitor the construction phase to ensure that, so far as is reasonably practicable, construction work is carried out without risks to health and safety.
We concluded that NNB GenCo’s strategic leadership for nuclear site health and safety culture needs to be strengthened as our findings and observations indicate shortfalls in the implementation of existing arrangements. This includes engaging with the contractors, cascading the learning from incidents to construction workers, and strengthening of measurement and monitoring to secure the health and safety of any person affected by the project.
Based upon the key findings described my judgement for the rating of relevant inspection areas is as follows:
- Nuclear safety – GREEN
- Nuclear security – GREEN
- Conventional health and safety – AMBER
I have therefore concluded that an overall inspection rating of AMBER is appropriate.
The shortfalls regarding nuclear site health and safety culture will be taken forwards as follows:
- For those matters already captured by existing regulatory issues, any improvements will be monitored through oversight of these issues.
- Regarding strategic leadership for nuclear site health and safety culture, as this is part of a theme previously identified and is already an area of focus, it will be addressed as a part of ONR’s wider regulatory engagement on this topic.
- Advice was provided to NNB GenCo regarding the key observations that we made during this inspection.
- The remaining observations are either already dealt with or will form intelligence for our future regulatory engagements.