Date(s) of inspection:
- May 2023
Aim of inspection
The aim of the inspection was to gain confidence in the preparation activities by NNB Generation Company (HPC) Ltd (NNB GenCo) / Edvance and Framatome ahead of the protection system (PS) factory acceptance testing (FAT) at Reference Condition (RC) 2 (V2). The inspection sampled evidence from the activities identified from the lessons learned as a result of the FAT activities in completion of RC 1.2 (V1) testing of the PS. The inspection also aimed to gather key evidence required to close out an extant regulatory issue (RI-10454) raised after an inspection examining the Class 1 PS V1 test bay.
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 presented, areas of good practice were identified, relating to the people, processes and outcome with regard to implementing the lessons learned from the protection system (PS) version 1 (V1) factory acceptance testing (FAT) in the preparation for delivery of PS V2 FAT, notably:
- personnel performing duties which may affect safety are suitably qualified and experienced persons (SQEP);
- the licensee has produced and updated (based on lessons learned) and demonstrated specific processes evidenced by the TXS based severe accident instrumentation and control (SA I&C)
- which will facilitate verification and validation (V&V) activities (V&V and test bay policies) during the delivery of the PS V2 FAT at test bay; and
- the approach will enable the production and demonstration of the Hinkley Point C (HPC) safety case.
NNB GenCo and Framatome adequately demonstrated implementation of the PS V1 test bay lessons learned to address regulatory issue RI-10454 raised during a previous inspection.
I found one minor Licence Condition (LC) 17 (management systems) shortfall relating to the use of the early involvement process (EIP) for approval and configuration control of test procedures that is currently not formalised within the licensee’s integrated management system (IMS). The licensee has committed to ensuring the EIP will be formalised in the IMS and to undertake an independent audit of the process. I have raised regulatory issue RI-11405 to track these commitments.
I judge that an inspection rating of green (no formal action) is appropriate for LC12: duly authorised and other suitably qualified and experienced persons. This is because I am content with the SQEP arrangements in place that ensure only SQEPs perform duties which may impact safety (in this case V2 testing of the PS at test bay) are adequate.
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 test bay.
I judge that an inspection rating of green (no formal action) is appropriate for LC17: management systems. In demonstrating its intelligent customer role, I found that the licensee has specified what needs to be done and implemented the lessons learned to management systems to address RC1.2 issues to support the PS (RC2) V2 test bay campaign. Resolution of the minor issue will be monitored through a level 4 regulatory issue.