Date(s) of inspection:
- March 2023
Aim of inspection
The aim of this inspection was to sample NNB Generation Company (HPC) Ltd’s (NNB GenCo) arrangements, and the implementation of its arrangements, for the operation of the first chemical laboratory at the Hinkley Point C (HPC) site. The laboratory is intended to deliver the sampling and analysis required to support the provision of demineralised water of an appropriate specification for the flushing of components following their installation, and to support commissioning of the first systems (this is likely to include sampling and analysis of oils associated with the auxiliary transformers).
It is important that adequate arrangements are in place so that the laboratory can deliver sampling and analysis of an appropriate quality to support the commissioning process, as well as other nuclear safety related site activities. The inspection sampled the relevant arrangements (including for training, laboratory availability, quality assurance (QA)/quality control (QC) and supporting documentation) to gain confidence in the readiness of the organisation to begin sampling and analysis prior to the start of laboratory operations later in 2023. The inspection also included a walkdown of the operational laboratory to observe the adequacy of the implementation of the arrangements.
Currently, first samples are due to be taken and analysed during 2023. This was therefore the first of two inspections – this inspection aimed to provide evidence supporting the readiness of NNB GenCo to begin conducting sampling and analysis. A second inspection, due later in 2023, will inspect the facility once analysis of samples has begun.
Subject(s) of inspection
- LC 12 – Duly authorised and other suitably qualified and experienced persons – Rating: Green
- LC 14 – Safety documentation – Rating: Green
- LC 24 – Operating instructions – Rating: Green
Key findings, inspector’s opinions and reasons for judgement made
I judged the adequacy of NNB GenCo’s arrangements and their implementation against the expectations associated with Licence Condition (LC) 12 (suitably qualified and experienced personnel (SQEP)), LC14 (safety documentation) and LC24 (operating instructions). As the chemistry laboratory was not due to operate for at least six months this inspection was aimed at gaining confidence that preparations are proceeding adequately. As such, the degree with which NNB GenCo adhered to the licence conditions reflects this fact, and they were used to inform the inspection judgement.
NNB GenCo has developed a number of plans to ensure that the correct training material and courses are in place to ensure that the team are sufficiently SQEP in order to adequately operate the first chemical laboratory on site. Although there is a risk regarding the provision of more longer term training requirements, of which NNB GenCo were aware, I was content that sufficient progress is being made ahead of first analysis.
NNB GenCo has also yet to undertake an adequate resource mapping exercise, to demonstrate that sufficient resources will be in place for the new laboratory. However, I was reassured with the progress made in the identification of roles and tasks, and I gained confidence that when such a mapping exercise is conducted, it would demonstrate sufficient resources are available.
In respect of safety documentation, NNB GenCo provided documents that set out the requirements of the laboratory, and plans that demonstrated how the laboratory will meet these requirements. I sampled plans that detailed the steps necessary to set up the laboratory, and to complete all of the relevant training and document production activities. NNB GenCo has committed to a rigorous assurance self-review and independent peer review prior to using the laboratory to ensure that all necessary steps have been identified and completed. I was therefore content with NNB GenCo’s approach.
Whilst only a few Operating Instructions have been produced to date, NNB GenCo was able to demonstrate a robust procedure for the many instructions that will be needed for the laboratory, and the document production plan indicated that the process remains on track ahead of the first analysis. NNB GenCo also provided evidence to demonstrate how QC and validation activities will be undertaken. Despite the gap concerning QA grading of activities, overall I was content with the NNB GenCo’s approach.
Overall, I consider that NNB GenCo is making good progress ahead of the first analysis. Despite some areas for improvement, and uncertainty about the provision of the temporary laboratory, I rated LCs 12, 14 and 24 as GREEN (no formal action) to be warranted for this inspection. I will track progress with the actions raised on NNB GenCo during this inspection through my routine interactions with the licensee and via part two of this inspection, which I intend to carry out once the temporary laboratory is operational.