NNB GENERATION COMPANY LTD

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1 NNB GENERATION COMPANY LTD COMPANY DOCUMENT HINKLEY POINT C MANAGEMENT PROSPECTUS 2011 Published in the United Kingdom by NNB Generation Company Limited (NNB GenCo), 90 Whitfield Street - London, W1T 4EZ. All rights reserved. No part of this publication may be reproduced or transmitted in any form or by any means, including photocopying and recording, without the written permission of the copyright holder NNB GenCo, application for which should be addressed to the publisher. Such written permission must also be obtained before any part of this publication is stored in a retrieval system of any nature. Requests for copies of this document should be referred to Head of Business Architecture, NNB Generation Company Limited (NNB GenCo), 90 Whitfield Street - London, W1T 4EZ. The electronic copy is the current issue and printing renders this document uncontrolled. Controlled copy-holders will continue to receive updates as usual.

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4 MANAGING DIRECTOR S STATEMENT This for Hinkley Point C is written at a time of exciting developments in Nuclear Power in the UK. NNB Generation Company Limited was set up in 2009 to carry out the safe design, construction and operation of four EPR in the UK. While the EPR design is new to the UK, it is based on tried, tested and proven technology through over 30 years of safe and successful operation of similar designs in France. As part of the EDF Group, we are uniquely able to make full use of the vast experience gained from the design, construction and operation of these stations. This and its associated dossier will underpin the ability of NNB Generation Company Limited to hold, manage and operate to a Nuclear Site Licence, an environmental permit and other arrangements with regulators thereby fulfilling its obligation with regard to Safety, Environment, Security, Health, and Quality. NNB Generation Company Limited through its Directors and Managers, together with its shareholders EDF Energy and Centrica, understands its obligations under the Nuclear Installations Act 1965 (as amended) and Environmental Permitting (England and Wales) Regulations 2010, as well as its fundamental duties under other legislation including the Health and Safety at Work Act 1974, Environmental Protection Act 1990, Environment Act 1995, the extensive regulations made under these and other environmental, safety, health and security statute. The Directors of NNB Generation Company Limited understand and accept both their absolute obligations under the nuclear licence and environmental permitting as well their more general duty to ensure the health, safety and welfare at work of its employees and the public. This and its associated dossier set down the corporate governance, assurance and management system arrangements in place to ensure compliance with nuclear licensing and environmental permitting at Hinkley Point C. It also covers arrangements for complying with other environmental, safety, security and health requirements. In carrying out our mission, we are committed to our work being undertaken in ways that are safe and secure, transparent and environmentally responsible. Finally, the events at the Fukushima nuclear power plant in Japan remind us all of the hazards associated with nuclear power generation, my management team and I are aware of both our personal, moral and legal duties for the protection of people and the environment. We will lead by example and encourage and support behaviours to deliver a culture where safety and care for the environment underpins all we do. Humphrey Cadoux-Hudson Managing Director NNB Generation Company Limited Page 4 of 58

5 TABLE OF CONTENTS 1 INTRODUCTION References and Definitions NNB GENCO The Company NNB GenCo NNB GenCo Vision and Values Organisation of NNB GenCo The Role of the Architect Engineer and Responsible Designer Architect Engineer Responsible Designer The NNB GenCo Board Responsibilities Governance, Risk Management and Internal Control Safety Governance Operations Membership of the Board Managing Director Project Director HPC Client Construction Director EPR Architect Director Planning and External Affairs Director Finance Director Human Resources Director Non Executive Directors Company Secretary NNB GenCo Executive Responsibilities of the Executive Membership of the Executive Safety Director HPC Site Construction Director Pre-Operations Director Committees Safety, Health and Environment Committee Nuclear Safety Committee Construction Committee Operational Control Committee The Investment Committee THE UK EPR FOR HINKLEY POINT C The Hinkley Point C Site Basic EPR Description Related Permissions, Consents and Permits Funded Decommissioning Programme Third Party Nuclear Liability...31 Page 5 of 58

6 3.3.3 Generic Design Assessment Infrastructure Planning Commission Environmental Permits Overall Phasing Hinkley Point C Hold Points HPC Site Organisation MANAGEMENT SYSTEM Background Process Categories Management Processes Business Planning & Investment Governance Assurance Continuous Improvement Support Processes Documents and Records Human Resources Competence and Training External Communications Finance Information Management Properties and Facilities Health, Safety, Environment and Security Core Processes Project Management Design Procure Manufacture Construct Commission Operate Decommission Consents, Permits and Licences ORGANISATIONAL CAPABILITY Nuclear Baseline Control of Organisational Change Design Authority Organisational Learning Knowledge Management Intelligent Customer Capability FORWARD WORK PLAN CONCLUSION...52 APPENDIX A FIGURES Page 6 of 58

7 APPENDIX B NNB GENCO HEALTH, SAFETY, ENVIRONMENT AND QUALITY POLICY...58 TABLE OF FIGURES Figure 1: Corporate Structure, ownership and HPC land leases to NNB GenCo...53 Figure 2: Hinkley Point C Proposed Nuclear Licensed Site Boundary (solid red line)...54 Figure 3: Illustrative view of the Hinkley Point C site...54 Figure 4: NNB GenCo Board...55 Figure 5: NNB GenCo Executive Team...55 Figure 6: Board Committees...56 Figure 7: NNB GenCo Management System Hierarchy...56 Figure 8: NNB GenCo Process Groups...57 Page 7 of 58

8 1 INTRODUCTION 1. This (MP) has been prepared by NNB Generation Company Limited (NNB GenCo) as part of the application for a Nuclear Site Licence (NSL) and Radioactive Substances Regulation environmental permit for the installation and operation of two EPR nuclear power reactors at Hinkley Point in Somerset. NNB GenCo was incorporated as a private limited company on 17 June Its Articles of Association are dated 16th September 2009 [Section 3.1 of the NSL application dossier]. 2. The MP provides an overarching demonstration of how NNB GenCo will manage nuclear safety, radiological safety, environmental protection, industrial safety and physical security (hereafter referred to as Safety), and quality. The MP shows how the organisation and arrangements are appropriate now and will be in the future as the project progresses. In particular it will show (in conjunction with the Nuclear Baseline [Ref 1] (NB)) that: NNB GenCo is appropriately constituted as a Company, including the structure of the NNB GenCo Board of Directors and Executive Team; NNB GenCo has appropriate governance arrangements in place to ensure and assure Safety; NNB GenCo has oversight and control of its activities that may have an impact on Safety; NNB GenCo has sufficient, competent resources to be an Intelligent Customer (IC) and manage its activites; Nuclear safety related roles and posts have been identified for the baseline organisation and sufficient, competent resources will be available at the right time to fulfil those as the organisation develops; NNB GenCo will have control of design and pre-construction activities; and There is a suitable Integrated Management System (IMS) to enable the Company to operate and fulfil its mission. 3. NNB GenCo s core activities are the design, procurement, manufacturing, construction, commissioning, operation and eventual decommissioning of new nuclear power plants in the UK. NNB GenCo plans to build and operate four EPR s in the UK. There will be twin units at Hinkley Point C (HPC) in Somerset and Sizewell in Suffolk. It is intended that NNB GenCo will be the nuclear site licensee and environmental permit holder for these sites and will be supported by Electricité de France SA (EDF SA) including EDF s nuclear engineering division (Division Ingénierie Nucléaire or DIN ), in particular as Responsible Designer (RD) and Architect Engineer (AE). 4. The hazards in this pre-construction phase are largely from latent hazards (those which may appear in future phases as a result of work now) which may be introduced during the design stage or manufacturing activities and industrial hazards from site. 5. NNB GenCo has processes in place to control the design, assess it and accept it as well as having the EDF SA design processes. Safety Cases will be produced to support the design and demonstrate that the design is robust with the highest standards of nuclear safety and environmental management. 6. Industrial hazards are managed appropriately through risk assessment and proper authorisation of work. Page 8 of 58

9 7. The MP and NB consider the early activities NNB GenCo will undertake during the preconstruction phase, including the management of design and safety case development, procurement, site preparation and preliminary works. The MP and NB will be reviewed and revised to fully reflect the requirements of construction, commissioning and later for full operation. 8. NNB GenCo is committed to setting high standards in nuclear safety that deliver best practice, considering International Atomic Energy Agency (IAEA) requirements and the advice of organisations such as the World Association of Nuclear Operators (WANO) and the Institute of Nuclear Power Operators (INPO) in developing these standards. Guidance specific to a MP has been considered and this specifically includes guidance given by the Office for Nuclear Regulation (ONR) [Refs 2, 3, 4, 5, 6, 7 and 8], the Environment Agency (EA) [Ref s 9 and 10] and joint regulatory guidance [Ref 11]. 9. NNB GenCo has developed an overarching Health, Safety, Environment and Quality Policy (see Appendix B). The underpinning management arrangements reflect best practices, processes and procedures as reflected in IAEA requirements, ISO standards (e.g. ISO 9001, 14001, 18001, 27001) and guidance from the EA and Health and Safety Executive (HSE), as well as its parent EDF SA, the world s largest owner and operator of nuclear power plants. 10. NNB GenCo will ensure that excellence in Safety are at the forefront of what we do throughout the organisation. This will be achieved through: Robust standards and processes based on national and international best practice and guidance, as well as legislative compliance; Implementing those standards and processes with competent people; Control and oversight of its activities; The proactive identification and mitigation of Safety hazards; Challenging ourselves to seek opportunities to improve, and ensuring systematic robust challenge from the Independent Assessment Challenge and Oversight (IACO) and review of designs and safety documentation; Challenge from Safety Committees like the Nuclear Safety Committee (NSC) and Safety Health and Environment Committee (SHEC); Actively seeking and learning from others experience internationally, nationally and within the EDF Group to ensure feedback and experience are identified, assessed, action taken to prevent similar incidents and that experience is shared; and Ensuring a good safety culture where challenge and learning are encouraged. 11. The Independent Assessment, Challenge and Oversight (IACO) team working for the Safety Director provide the essential Independent Challenge within NNB GenCo, and communicate through the Safety Director to the Board and Executive. 12. The Board is systematically updated on Safety, challenge and feedback/experience. In this way the Board are fully informed to enable proper consideration of Safety management and help ensure conservative decision making. 13. NNB GenCo recognise that the organisation will change through Construction, Commissioning and into Operation to reflect the activities and hazards for that phase and the need to maintain a capable licensee organisation. Page 9 of 58

10 14. The overall resource requirements and manpower needs within NNB GenCo are managed through the Company s resource strategy [Ref 12] and the supporting Medium Term Plan. Maintaining a capable licensee organisation with be achieved through: Recruitment of staff commensurate with the Resourcing Strategy [Ref 12] and the use of links with EDF Energy Nuclear Generation Ltd and EDF SA to bring in technical staff into NNB GenCo; Competency Assessment and Training; Succession Planning; and Managing Change. 15. NNB GenCo have developed processes and an organisation to support the safe procurement of materials and services relating to the build of HPC. They demonstrate how NNB GenCo: Assures that materials and services delivered by the supply chain meet required standards; Correctly identify and specify work requirements and standards; Identify suitably qualified and experienced potential tenderers; Evaluate and select the right Contractor(s); Demonstrate Intelligent Customer capability; Identify and control interfaces with AE procurement processes via Interface Specifications; Identify appropriate interfaces with other NNB GenCo departments such as Design Authority and Construction; and Control procurement. 16. The Architect Engineer (AE) will support the procurement process, however NNB GenCo have control and accountability in all the steps. 17. The Company Manual [Ref 13] describes in detail the way in which the organisation is governed. It sets out the Company mission and values and summarises the principal governance arrangements approved by the NNB GenCo Board. 18. Other documents, as summarised in the Head Document [Ref 14], provide additional information and the Head Document is a route map for the application dossier. Collectively the documents in the dossier meet the requirements of the licence application process as defined in The processing of licence applications for new nuclear sites [Ref 5] and The licensing of nuclear installations [Ref 4], aimed at organisations seeking to become a UK nuclear site licensee. 19. The MP demonstrates that NNB GenCo is a competent nuclear site licensee and environmental permit holder, progressing through construction and commissioning to operation to be a world class owner and operator of nuclear power plants. Page 10 of 58

11 1.1 References and Definitions Ref Title Location Document No. 1 NNB GenCo Nuclear Baseline v2 EDRMS NNB-HRE-ASS HSE NSD Safety Assessment Principles for nuclear facilities, HSE Website clear/saps/ 3 Function and content of a safety management prospectus (HSE internal guidance T/AST/072 Issue 1). HSE Website /internalops/nsd/tech_as st_guides/tast072.htm 4 The licensing of nuclear installations HSE Website clear/notesforapplicants. pdf 5 HSE The processing of licence applications for new nuclear sites, INS/036 Issue 1. HSE Website /internalops/nsd/inspectio n/ins036.htm 6 Licensee design authority capability T/AST/079 Issue 1 HSE HSE Website /internalops/nsd/tech_as st_guides/tast079.htm 7 Procurement of nuclear safety related items or services T/AST/077 HSE HSE Website /internalops/nsd/tech_as st_guides/tast077.htm 8 Licensee use of contractors and intelligent customer capability T/AST/049 Issue 3 HSE HSE Website /internalops/nsd/tech_as st_guides/tast049.htm 9 Radioactive Substances Regulation: Management Arrangements at Nuclear Sites Version 2 Environment Agency EA Website uments/business/geho 0709BQXB-E-E.pdf 10 Radioactive Substances Regulation Environmental Principles, The Environment Agency Version 2.0 EA Website uments/business/geho 0709BQXB-E-E.pdf 11 Guidance on the Production and Use of an Integrated Guidance Note Radioactive Substances Regulation HSE and Environment Agency. EA Website uments/business/geho 0709BQWX-E- E_(2)_(2).pdf 12 Nuclear New Build (GenCo) Resourcing Strategy Issue 1, January 2010 Held by NNB GenCo HR Held on NNB GenCo system. 13 NNB GenCo Company Manual EDRMS NNB-OSL-MAN Application for a Nuclear Site Licence for Hinkley Point C - Head Document EDRMS NNB-OSL-REP Internal Challenge and Oversight Strategy EDRMS NNB-OSL-STR Terms of reference and membership of the NNB Nuclear Safety Committee. EDRMS NNB-OSL-TOR NNB GenCo Company Procedure Define, Manage and Release Key Hold Points. EDRMS NNB-OSL-PRO Page 11 of 58

12 Ref Title Location Document No. 18 NNB GenCo Management System Manual EDRMS NNB-OSL-MAN Forward Work Plan for Hinkley Point C Nuclear Site Licence Application EDRMS NNB-OSL-PLN AE AGR BAT BS CAP CNS DA DAC DCO DECC DIN EA Term / Abbreviation EDF Energy Nuclear Generation Ltd EDF SA EDRMS EPR FDP FWP GDA HPA HPB HPC HR HSE IACO IAEA IC IEC IMS INPO IPC IS ISO ITA KM KPI LWR MD MP MWh NB NDA NIA NNB GenCo Architect Engineer Advanced Gas-Cooled Reactor Best Available Technique British Standard Corrective Action Plan Civil Nuclear Security Design Authority Design Acceptance Confirmation Development Consent Order Department of Energy and Climate Change Definition Division Ingénierie Nucléaire, The engineering division of EDF SA Environment Agency From 1 July 2011, EDF Energy Nuclear Generation Limited, Company Number whose registered office is at Barnett Way, Barnwood, Gloucester, GL4 3RS, formerly known as British Energy Generation Limited (BEGL). Electricité de France Société Anonyme Electronic Document and Record Management System The Pressurised Water Reactor developed and trademarked by AREVA Funded Decommissioning Programme Forward Work Plan Generic Design Assessment Hinkley Point A Hinkley Point B Hinkley Point C Human Resource Health and Safety Executive Independent Assessment, Challenge and Oversight International Atomic Energy Agency Intelligent Customer International Electro-Technical Commission Integrated Management System Institute of Nuclear Power Operators Infrastructure Planning Commission Information System International Organisation for Standardisation Independent Technical Assessment Knowledge Management Key Performance Indicator Light Water Reactor Managing Director Mega-Watt Hour Nuclear Baseline Nuclear Decommissioning Authority Nuclear Installations Act (1965) as Amended NNB Generation Company Limited Page 12 of 58

13 Term / Abbreviation NSC NSIP NSL NSRAC OCC OHSAS ONR OPEX PCER PCSR PUK PWR QA RD RSR SHEC SHEQ SOCC SoDA SSER SZC UK WANO WENRA Definition Nuclear Safety Committee Nationally Significant Infrastructure Projects Nuclear Site Licence Nuclear Safety Review and Advisory Committee Operational Control Committee Occupational Heath and Safety Management System Office for Nuclear Regulation Operating Experience Pre-construction Environmental Report Pre-Construction Safety Report The UK EPR team within EDFSA Pressurised Water Reactor Quality Assurance Responsible Designer Radioactive Substances Regulation Safety Health and Environment Committee Safety, Health, Environment and Quality Statement of Community Consultation Statement of Design Acceptability Safety, Security and Environmental Report Sizewell C United Kingdom World Association of Nuclear Operators Western European Nuclear Regulators Association Page 13 of 58

14 2 NNB GENCO 2.1 The Company NNB GenCo 20. NNB Generation Company Limited (NNB GenCo) was incorporated on 17 June 2009 as a private limited company, NNB GenCo s company number is and its registered office is at 40 Grosvenor Place, London SW1X 7EN, with its principal office at the Qube, 90 Whitfield Street, London W1T 4EZ. 21. NNB GenCo is a wholly-owned subsidiary of NNB Holding Company Limited ( NNB Holding Company ). NNB Holding Company is a joint venture held 80% by EDF Energy Holdings Limited, and 20% by Centrica plc through its subsidiary, GB Gas Holdings Limited. 22. This corporate structure is shown in Figure NNB GenCo is structured to have sole responsibility for licensed activity related to the design, construction, commissioning, operation and eventual decommissioning of UK EPR s. NNB GenCo shall have control of all activities required to be conducted under its NSL and environmental permits as well as other safety, security, transport and environmental legislation. 24. Adequate financial resources will be made available to NNB GenCo by its shareholders to enable NNB GenCo to meet its NSL and other obligations. 25. EDF Energy Holdings Limited is the owner of the EDF Energy Nuclear Generation group of companies, which in turn own and operate 15 nuclear power reactors on 8 sites in the UK, including Hinkley Point B (HPB). The EDF SA Group of companies also operates 58 nuclear power reactors in France, with a combined capacity of approximately 63 GWe. EDF SA is the largest nuclear utility in the world. 26. EDF SA and Areva are the joint Requesting Parties for the Generic Design Assessment (GDA) for the EPR. Additionally, NNB GenCo will enter into agreements for EDF SA to serve as the RD and AE. These agreements will ensure NNB GenCo can fulfil its responsibilities as a nuclear site licensee and permit holder as an intelligent customer for those services. 27. Further details about the Company and its Parents are set out in the NNB GenCo Company Manual NNB GenCo Vision and Values 28. NNB GenCo s Vision is Leading the way in building a fleet of safe, reliable nuclear power stations without costing the earth. 29. Our Values drive our operating principles and our ambitions, and they are fundamental to the way we work. These values, which we share with the other members of the EDF Group, are: Respect for individuals; Respect for the environment; Excellent performance; Social responsibility; and Integrity. Page 14 of 58

15 30. The NNB GenCo Health, Safety, Environment and Quality Policy explains that safety and care for the environment are our overriding priorities and we are committed to achieve this through the excellence of our quality arrangements and by providing appropriate training to employees. 31. More information may be found in the NNB GenCo Company Manual Organisation of NNB GenCo 32. There are seven Executive Directors on the NNB GenCo Board, being the Chairman and Managing Director, the Project Director HPC, the EPR Architect Director, the Client Construction Director, the Director of Planning and External Affairs, the Finance Director and the Human Resources (HR) Director. Two Non-Executive Directors have been appointed and a third will be appointed prior to granting of the NSL. 33. The Safety Director and Company Secretary will attend the Board. 34. Those Executive Directors, who are not currently employed by EDF SA, will be employed by NNB GenCo prior to granting of the NSL. 35. The EPR Architect Director and the Client Construction Director are both employed by EDF SA; as Directors of NNB GenCo they, like the other Directors, will be solely focused on the HPC project and have no conflicts of interest with the mission of NNB GenCo. 36. However, to reinforce this, NNB GenCo and EDF SA will enter into a secondment agreement with the EPR Architect Director and the Client Construction Director. 37. Therefore, NNB GenCo, has in place a Board structure ready to become a Licensee and controlling mind, having a Board that is solely focused on the mission of NNB GenCo with no other conflicts from other companies within the EDF Group. 38. All other personnel below Board level will be seconded into NNB GenCo from EDF Energy plc or EDF SA. This will be via two secondment agreements; one between NNB GenCo and EDF Energy plc, and one between NNB GenCo and EDF SA. 39. The secondment agreements will ensure personnel seconded into NNB GenCo are embedded into the organisation, effectively as employees. 2.2 The Role of the Architect Engineer and Responsible Designer 40. NNB GenCo will be the nuclear site licensee and environmental permit holder for HPC. It will be supported by its parent Company, Electricité de France SA (EDF SA) including EDF SA s nuclear engineering division (Division Ingénierie Nucléaire or DIN ). 41. EDF SA will be appointed by NNB GenCo as the Architect Engineer (AE) and Responsible Designer (RD) for HPC with appropriate arrangements in place to ensure NNB GenCo has overall control and is an intelligent customer for those areas. 42. Both appointments may be covered by a single agreement up to the point where the AE role ceases wherein a specific RD agreement will be put in place. 43. The EPR Architect Director acts as the interface with the AE organisation on all aspects of the design and construction including procurement, detailed design and modifications. Page 15 of 58

16 44. NNB GenCo will have control of activities being undertaken on its behalf and be an IC for the services provided. 45. The NNB GenCo Design Authority (DA), as an IC will: Control, review and accept designs; Control design changes process; Own or have access to design and supporting documents; and Ensure knowledge is transferred from the AE and RD to NNB GenCo Architect Engineer 46. The role of the AE is to manage the production of the design, to manage the early stages of the procurement process, development of the construction schedule and management of the interfaces. The design is managed from basic design through to detailed design. It is the role of the AE to integrate each aspect of the design, by DIN department, building and system. Additionally, the AE will support NNB GenCo in project management, contract management, manufacturing and construction surveillance and in commissioning. The AE consists of the UK EPR project team (PUK) and specialist resource within EDF SA. The AE role will cease, following initial operation. 47. EDF SA will be appointed as the AE through an AE Agreement which will be put in place prior to granting of the NSL. The agreement will identify the scope of services offered by the AE, which will include: 48. Engineering : Safety Case support; Delivery of basic and detailed design and manufacturing specifications and engineering; Checking the overall consistency of the design between the various contractors and suppliers; Manufacturing surveillance and conformity assessment services; Providing feedback and experience from other nuclear projects; Support to NNB GenCo in the management of relevant contracts, including design contracts, up to formal transfer of such contracts to NNB GenCo; and Delivery of engineering documentation. 49. Procurement: Where required by NNB GenCo, undertaking and managing the procurement process up to NNB GenCo approval of the procured contract, follow-up of manufacturing / inspections; and Manufacturing/Inspection Quality Assurance (QA) support. 50. Construction: Initial Construction Schedule; and Construction/commissioning support and backup. 51. AE activities will be integrated in the overall schedule of the project. The AE will perform the project control of its own scope in an integrated manner with NNB GenCo. 52. NNB GenCo will define the services and control the delivery and schedule of those services from the AE. Interface specifications will be in place prior to the agreement Page 16 of 58

17 which describe the requirements from both EDF SA and NNB GenCo for particular aspects Responsible Designer 53. The role of the RD is to hold the detailed knowledge of the design. The RD will maintain the codes and standards, contribute to the design process at the upper levels and to ensure the validity of the detailed design at the lower levels. During operation, the RD will provide an operations and engineering support function to the Licensee. The RD is that organisation within EDF SA that holds knowledge of the EPR. The RD role will continue throughout the HPC lifecycle. 54. EDF SA will be appointed as the RD prior to NSL Granting, by a formal agreement. The scope of the RD will be for the plant and equipment within the NSL boundary, apart from those aspects which will be covered by NNB GenCo Engineering (includes roads, networks and the operational services centre). 2.3 The NNB GenCo Board Responsibilities 55. The NNB GenCo Board is responsible for the governance of the Company, setting the Company s strategic aims, providing the leadership to put these aims into effect and supervising the management of the business to ensure effective implementation of NNB GenCo s strategy. The Board is also responsible for overseeing effective safety arrangements; overseeing operational performance against company objectives; and overseeing the implementation of effective systems of governance, risk management and internal control. The Board is accountable for satisfying all the Company s statutory and regulatory requirements, specifically with respect to maintaining effective control over Safety. The Board reports to the shareholders on its stewardship of the Company. 56. Effective governance of the Company depends upon the leadership and behaviours of the NNB GenCo Board. The Board is accountable for all safety-related decisions and is responsible for all safety-significant activities. The Board ensures that safety, security and environmental issues are a part of every meeting of the Board and integral to how the Board works. The Board is supported in all safety, environmental protection, security, health and quality by the Safety Director. This ensures that all decisions taken by the Board are taken after full consideration of the implications of the decision. The Board ensures that the same culture of leadership and management is promulgated, enacted and effective throughout the Company. 57. More specifically, the NNB GenCo Board is responsible for the following: Governance, Risk Management and Internal Control 58. The NNB GenCo Board in accordance with its terms of reference has responsibility for directing the affairs of NNB GenCo, including: Setting the Company s Project Vision, Values and Strategic Performance; Establishing an organisational and corporate governance structure and regularly reviewing its effectiveness; Overseeing safety governance arrangements; Overseeing operational performance; Page 17 of 58

18 Overseeing the control of the design, construction and operation of its nuclear sites; Establishing a system of internal controls and regularly reviewing their effectiveness; Approving policies and procedures for the effective identification, assessment, management and monitoring of material risks within NNB GenCo and reviewing the Register of principal risks quarterly to ensure adequate risk management actions have been implemented; Overseeing the integrity of NNB GenCo s financial statements and compliance with all legal and regulatory requirements, approving key capital investments or divestments; and Monitoring material risks and ensuring adequate risk management actions are implemented Safety Governance 59. NNB GenCo, through its Board, has responsibility for Safety within NNB GenCo. It is responsible for Establishing and implementing effective safety, health and environmental protection policies; Establishing and overseeing an effective safety, health and environmental protection culture, specifically implementing a strong nuclear safety culture; Overseeing that sufficient competent persons and other resources are provided to execute all nuclear licensed, permitted and consented activity; Overseeing the Company s safety performance, including receiving and reviewing reports and implementing recommendations from the SHEC; Overseeing the implementation of adequate arrangements to control any change to NNB GenCo s organisational structure or resources which may affect Safety; Ensuring that Safety takes priority over commercial performance objectives; and Reviewing the effectiveness of NNB GenCo s security arrangements. 60. NNB GenCo Board and Safety Director are supported by the SHEC and NSC supplying advice, reports, information and assurance to the Board. 61. The Safety Director will have in place an independent assurance function (called the IACO team, [Ref 15]) to maintain oversight of NNB GenCo s activities and will report on Safety and overall organisational performance to the Board and its supporting committees as appropriate. 62. In the current phase of the project the Design Authority (under the Project Director HPC) has responsibility for the Independent Technical Assessment (ITA) of safety documentation Operations 63. The NNB GenCo Board has responsibility for overseeing the control of the design, construction and operation of its nuclear plants. It is responsible for: Producing a company business plan for each financial year and recommending an annual budget to the NNB Holding Company Board; Page 18 of 58

19 Informing the NNB Holding Company Technical Committee on all relevant information to allow it to assess the progress of NNB GenCo projects; Overseeing the implementation of a system of Key Performance Indicators (KPIs) that facilitate effective measurement of operational performance; Recommending key contracts to the NNB Holding Company Board; Approving key capital investment (divestment) decisions or recommending to the NNB Holding Company Board for approval as appropriate; Establishing a human resource and information systems resource management strategy; and Approving contributions to the Funded Decommissioning Programme (FDP) to meet decommissioning and other non-contracted nuclear liabilities relating to the Company s installations, and for ensuring that the contributions are paid into the FDP. 2.4 Membership of the Board 64. Figure 4 below shows the structure and membership of the Board. The NNB GenCo Board has seven Executive Directors and currently two Non Executive Directors. These are: Chairman and Managing Director (MD); Project Director HPC; Client Construction Director; EPR Architect Director; Planning and External Affairs Director; Finance Director; Human Resources Director; and Two Non-Executives Directors with in depth experience in construction, nuclear regulation and strategy. 65. NNB GenCo will appoint a third Non-Executive Director prior to granting of the NSL with experience in nuclear safety. 66. The NNB GenCo Safety Director will attend all Board Meetings to provide the MD and Board with assurance and advice on all aspects of safety. 67. The NNB GenCo Company Secretary will also attend Board meetings. 68. Responsibility for Safety performance rests with the Board and Board members. 69. Responsibilities of the individual Board Members are set out in this Section, with emphasis on the Safety responsibilities, more information may be found in the NNB GenCo Company Manual. 70. To ensure that their respective roles are being carried out efficiently and effectively, all Board members will be collectively assessed on an annual basis against a set of agreed standards and competencies relevant to their role and assessed. 71. It should be noted that a Pre-Ops Director and Sizewell C (SZC) Project Director will be appointed later. Page 19 of 58

20 72. The Board shall maintain a Risk Register that covers the principal Company risks including safety, security, environmental and quality risks. The Board regularly review the Register, including the plans to reduce or mitigate any identified risks Managing Director 73. The MD is the Chairman of the NNB GenCo Board and is a member of the Board of NNB Holding Company Limited. 74. The MD is accountable to the Board for NNB GenCo s compliance with legislation including health, safety, security and environmental legislation. 75. As Chairman, he leads the Board and represents the Company externally. A key role is ensuring that the following areas are being satisfactorily achieved and monitored: The Board has the right balance of membership to provide leadership, vision and independent challenge; The Board sets the aims, strategy and policies of the Company and monitors the achievement of those aims by a set of improvement targets and Key Performance Indicators (KPIs); The Board receives the accurate, timely, high quality and clear information it needs to be effective; and The Company is interfacing well with its stakeholders and their views are being properly considered. 76. As MD he is responsible for the overall purpose of the UK EPR Project and leads the Executive team, overseeing and monitoring the Executive and their teams to ensure that the following key issues are being satisfactorily achieved: The Company operates safely and complies with legislative and regulatory requirements; Management of the Company to ensure targets and performance standards are met or put in place effective corrective measures; There is appropriate oversight and direction to management at all levels within the organisation; A business plan and annual budget is prepared for the NNB GenCo Board to review and approve as appropriate; Suitably qualified and experienced persons and other resources are provided throughout the Company; and Appropriate internal control processes, including quality assurance arrangements, are in place to ensure high levels of Safety within the Company Project Director HPC 77. The Project Director HPC has executive responsibility of all of aspects of the design, licensing, procurement, construction and commissioning of the HPC Project (the Project. The Project Director HPC s responsibilities are primarily focused on the safe delivery of the Project, in accordance with relevant laws and regulations, consistent with required quality standards, on schedule and budget. The Project Director HPC chairs the Construction Committee and the Operational Control Committee. 78. The Project Director HPC is responsible for: Page 20 of 58

21 Management of all on and off site construction and commissioning from ground preparation through to handover of plant at the pre-operational stage to the Pre-Operations Director; Engineering and procurement for the Project; Reviewing and accepting the design of the UK EPR, the control of modifications process and the development of the safety cases; Control and inspection of all aspects of the manufacturing and construction on the Project; Providing the interface management between NNB GenCo personnel, the AE, and the activities on the HPC site; Nuclear licensing, Security and environmental permitting and assessments; Lead interface with the ONR; and Project Management to safely deliver the Project on schedule and budget. 79. The Director has responsibilities which fall into the following areas: Construction: Management of all on and off site construction and commissioning from ground preparation through to handover of plant at the pre-operational stage. Engineering and Procurement: Responsible for NNB GenCo s processes, procedures and management of the detailed engineering design during the Construction and Commissioning Phases. Engineering of minor non nuclear plant and buildings at the HPC Site and associated developments. The lifecycle management of procurement contracts for all aspects of the Project, providing the interface between the AE, NNB GenCo and the activities on the HPC Site. Project Management: Management of the delivery of the Project, including project controls, planning, scheduling, cost management and risk management. The prime focus of the Project Management team will be to safely deliver the HPC Project on schedule and budget. Nuclear & Environmental Licensing and Security: Co-ordination of the relationship with Regulators, across all functions of NNB GenCo and the GDA process, to support the construction and commissioning of the EPRs at HPC. Management of the environmental and security assessments for NNB GenCo. Delivery of the Nuclear Site Licence (NSL) and Environmental Permits and other associated consents, ensuring effective communication with Regulators including the ONR and the EA. Design Authority: The DA are responsible for reviewing and accepting the design of the UK EPR, the control of modifications process and the development of the safety cases. The DA provides an integrated design authority capability, with support through interface agreements with such organisations as the NNB GenCo Environment team, the AE and the RD. Quality Control: Control and inspection of all aspects of the construction phase of the Project. Page 21 of 58

22 2.4.3 Client Construction Director 80. The Client Construction Director is responsible for: Supporting early identification and resolution of construction strategy issues; Providing feedback and experience from other relevant international projects including the Flamanville 3 project in France; Managing relationships with key suppliers, contractors and manufacturers; Identifying experienced EDF SA resource and skills to support HPC Project; Project Management of associated projects supporting NNB GenCo in its role as The Client ; and Oversight and advice on construction strategy, including waste and spent fuel facilities EPR Architect Director 81. The EPR Architect Director is responsible for: The design of the EPR power station model suitable for construction in the UK and specifically at HPC and SZC; The development of the construction schedule of the EPR design by the AE for transfer to the UK. The design review and acceptance will be through the NNB GenCo DA working for the Project Director HPC; Lead co-ordinator for UK EPR Project within EDF SA for design, engineering, procurement and schedule management; and Delivery of engineering and design activity being undertaken in France by EDF SA to meet UK EPR Project Schedule & UK Specifications Planning and External Affairs Director 82. The Planning and External Affairs Director is responsible for: Promoting the environmental, economic and sustainability case for nuclear generation; Leading the NNB GenCo interface with the Department of Energy and Climate Change (DECC), the Infrastructure Planning Commission (IPC), the local planning authorities, Environment Agency (EA) and Natural England and the Marine Management Office in respect of all planning matters; Contributing to the development of policy and producing the legal, financial and technical arrangements for the management and funding of nuclear liabilities; Supporting independent scrutiny of the Company s implementation of its environmental protection policies and arrangements; Developing and supporting the company s sustainability agenda; Developing and maintaining the FDP for the sites; Providing the external communications function for NNB GenCo including Community Relations for NNB GenCo; and Leading public consultation and planning application processes (IPC and local planning applications). Page 22 of 58

23 2.4.6 Finance Director 83. The Finance Director is responsible for financial matters within NNB GenCo. Key responsibilities include: Implementing financial policies and strategies for NNB GenCo; Developing an investment case to support the investment decisions of the new nuclear programme; Ensuring an integrated governance framework is maintained to support effective management of NNB GenCo; Financial Compliance Controls Function; Preparing annual accounts and reports as well as the financial reports required by parent companies; and The Finance Director also serves as the Chair of the NNB Investment Committee. The Finance Director has responsibility for the NNB GenCo Integrated Management System (IMS) Human Resources Director 84. The Human Resources Director is responsible for: Developing the NNB GenCo human resource policies; Developing and managing of the NNB GenCo s succession and resource planning and leadership development activities; Providing relevant information and proposals relating to remuneration, hiring and terminations; Co-ordinating employee relations and pay issues; Ensuring that processes are in place to effectively provide training and development for employees; Ensuring that there is appropriate HR support to all line managers in NNB GenCo, providing advice, support and coaching; Ensuring that the Company s responsibilities under the management of organisational change processes are properly carried out, making and ensuring implementation of adequate arrangements to control any change to the NNB GenCo organisational structure or resources which may affect nuclear safety; Working with the Board and senior managers to ensure that suitably competent persons and other resources are provided to execute the roles within the NB; and Developing and managing internal communications Non Executive Directors 85. An important addition to the NNB GenCo Board, are its Non-Executive Directors, who have in depth experience from the construction and nuclear industries, including both conventional and nuclear safety, nuclear regulation and corporate strategy. They provide intelligent advice and challenge to the Board and Board Committees having gained, over many years, much experience from within the construction and nuclear industries. Page 23 of 58

24 2.4.9 Company Secretary 86. The Company Secretary is responsible for administration of the Board and Board Committees. The Company Secretary is responsible to the Chairman for ensuring good practice in corporate governance. Key responsibilities include: Ensuring NNB GenCo complies with all relevant laws and regulations and operates to a high ethical standard; Ensuring the Board and Board Committees within NNB GenCo comply with legislative requirements and apply good corporate governance including meeting Companies Act requirements; In consultation with the Chairman, preparation of agendas for Board Meetings and preparation of Board Minutes; and Serving as Legal Counsel to NNB GenCo; responsible for the development and continuous training of the lawyers within NNB GenCo s Legal Department, providing legal advice and support to NNB GenCo, its Directors and Heads of Functions. 2.5 NNB GenCo Executive Responsibilities of the Executive 87. The Executive Team, headed by the MD, has responsibility for the day to day management of the business, to ensure that the Company operates safely and complies with legislative and regulatory requirements; that competent persons and other resources are provided throughout the Company; and that appropriate internal control processes, including quality assurance arrangements are implemented to ensure high levels of Safety within the Company. 88. The Executive Team is also responsible for ensuring that the individual management teams for which they are responsible, meet targets and performance standards set and that there is appropriate oversight and direction to management at all levels within the organisation. The Executive is responsible for preparing for the MD a business plan and annual budget for the NNB GenCo Board to review and approve as appropriate Membership of the Executive 89. The NNB GenCo Board will be supported by an Executive Team (shown in Figure 5), comprising: Managing Director; Safety Director; Project Director HPC; HPC Site Construction Director ; Client Construction Director; Pre-Operations Director; EPR Architect Director; Director, Planning and External Affairs; Finance Director; Page 24 of 58

25 HR Director; and Company Secretary. 90. Responsibilities of the Safety Director, HPC Site Construction Director and Pre- Operations Director are shown below: Safety Director 91. The Safety Director reports to the MD and has responsibility for: Preparation and Oversight of the implementation of a robust Health, Safety, Environment and Quality Policy and a Security Policy; Assurance of all health, safety, environment, quality and security matters for NNB GenCo; Organisational learning and the promotion of an effective safety culture within NNB GenCo, including Safety; Provision of safety, environment, security, health, and quality advice and guidance to the NNB GenCo Board and Executive Team; Provision of a strong assurance function within NNB GenCo including internal challenge and oversight; Regular reporting of safety, environment, security and quality performance to the MD, Board and Executive team, providing recommendations for continual improvement; Oversight of Business Continuity plans based on business risks; and The Safety Director attends each Board meeting to advise the Board on all matters concerning health, safety, the environment and quality matters and security issues. The Safety Director is a member of the Executive team and chairs the SHEC and is also responsible for the management of the SHEC and the NSC HPC Site Construction Director 92. The HPC Site Construction Director has full responsibility for the HPC Site and activities during construction and up until handover to the Pre-Operations Director. 93. The key responsibilities of the HPC Site Construction Director during the Pre- Construction phase are: Pre-construction planning for the construction phase; Creating and maintaining a culture of construction excellence including all aspects of safety, environmental management and security on the HPC site; and Establishing and Maintaining a site organisation to deliver the project and satisfy nuclear site licensing and environmental permitting requirements Pre-Operations Director 94. The Pre-Operations Director will be responsible for: Preparations for Operational activities; Being the customer lead for commissioning activities; and Delivery of Training within NNB GenCo. Page 25 of 58

26 95. This post will become the Operations Director prior to fuel arriving on site. (Note: this role is presently not filled.) 2.6 Committees 96. The Board is the controlling mind of NNB GenCo and in order to discharge its responsibilities it interacts with a number of Committees and associated bodies shown in Figure 6 and summarised below (full descriptions can be found in the NNB GenCo Company Manual): Safety, Health and Environment Committee 97. The SHEC is chaired by the Safety Director. The members of SHEC will bring experience and expertise in safety, health and environment matters relevant to NNB GenCo. 98. The SHEC shall meet at least quarterly and has the following principal responsibilities in relation to reviewing and making recommendations to the NNB GenCo Board on nuclear safety, industrial safety, occupational health and environmental protection: Reviewing the Company s nuclear safety culture and performance, health and environmental protection policies; Monitoring and reviewing; o Nuclear Safety; o Industrial Safety; o Occupational Health; and o Environmental performance Reviewing safety, health and environmental risk exposures in NNB GenCo s Risk Register; and Making recommendations or referring matters to the NNB GenCo Board within the scope of SHEC responsibilities (listed above), including recommending performance targets and any initiatives necessary. 99. The NSC may provide input to the SHEC Nuclear Safety Committee 100. The NNB GenCo NSC (and its predecessor the Nuclear Safety Review and Advisory Committee NSRAC) have been established in NNB GenCo since mid Terms of reference require the committee to advise the licensee on any safety and environmental matters referred to it by NNB GenCo, the HSE or other regulators The key role of the NSC is to advise the NNB GenCo Board on matters of nuclear safety and environment to ensure they are able to make informed decisions in their executive capacity. This is achieved by a brief from every meeting being produced by the NSC Chairman to the Board through the Safety Director The Chairman of the NSC also has direct access to the MD on safety and environmental issues Matters typically considered by the NNB GenCo NSC are: All matters required by or under the Nuclear Site Licence Conditions to be referred to a NSC; Page 26 of 58

27 Such arrangements or documents required by the NSL Conditions as the ONR may specify and any subsequent alteration or amendment to such specified arrangements or documents; Any matter on the site affecting safety on or off the site which the ONR may specify; and Any other matter which the Licensee considers should be referred to a NSC The terms of reference and membership of the NSC are in Ref Construction Committee 105. Oversees the successful delivery of four EPR plants, reviewing performance against safety, quality, time and budget objectives. It is chaired by the Project Director HPC The Construction Committee has the following principal responsibilities in relation to delivery of the UK EPR projects, and are more fully defined in the Company Manual: Overall Scope: Reviewing the effectiveness of the management of the delivery of the UK EPR, safely, to quality, on time and on budget; Recommending for approval remedial action required to ensure delivery of the UK EPR, safely, to quality, on time and on budget; Reporting to the NNB GenCo Board in relation to progress of UK EPR projects; Overseeing the adequacy of design modification control, ensuring the categorisation of modifications according to safety significance and the screening of modifications for other impacts on decommissioning liabilities or the environment; and Monitoring the key issues, risks and decisions across the co-ordination committees relevant to the Construction Committee. Reviewing plans, budgets, contracts; Reviewing the AE relationship; and Reviewing construction Operational Control Committee 107. The Operational Control Committee (OCC) is chaired by the Project Director HPC and the scope of the Operational Control Committee is the management of NNB GenCo resources, operational processes and the UK EPR design and associated systems The OCC has the following overall scope in relation to NNB GenCo : Reviewing design integrity, consistency with the nuclear safety case and adequacy of design modification control; Overseeing safety, security and environmental matters in relation to NNB GenCo s operations; Overseeing quality assurance programme effectiveness; Overseeing the development and management of the resources required to effectively support the operation of the UK EPRs; Page 27 of 58

28 Reviewing allocation of resources and operating expenditure within NNB GenCo and making recommendations to the NNB GenCo Board as appropriate; Overseeing the implementation of an adequate management system of processes and procedures to effectively support the operations of NNB GenCo; Monitoring the risks associated with NNB GenCo s operations and recommending risk mitigation actions as appropriate The Investment Committee 109. The Investment Committee is chaired by the Finance Director and its scope is to ensure that capital spend is in line with the UK EPR investment case and brings value for money while minimising risk The Investment Committee has responsibilities in relation to capital spend on procurement contracts, asset investments (or divestments) and business change projects. Page 28 of 58

29 3 THE UK EPR FOR HINKLEY POINT C 3.1 The Hinkley Point C Site 111. HPC will be located at Hinkley Point, on the north coast of the County of Somerset on Bridgwater Bay. It will be within the civil parish of Stogursey in the District of West Somerset. The grid reference of the approximate centre of the HPC site is ST The proposed site for HPC is located to the west and south of two existing nuclear installations, Hinkley Point A (HPA) and HPB. HPA is a two-unit Magnox nuclear power plant managed by Magnox Ltd. HPA is currently being decommissioned under the authority of the Nuclear Decommissioning Authority (NDA). HPB is a two-unit nuclear power plant utilising Advanced Gas-cooled Reactors (AGRs) that are operated by EDF Energy Nuclear Generation Ltd NNB GenCo intends to design, construct, commission, operate and decommission two UK EPR reactors on the HPC site The UK EPR s will be based on the Areva/EDF design being considered in the GDA process. The reactor design has been developed by Areva in partnership with EDF SA and is a third generation design which embodies experience from German and French Pressurised Water Reactor (PWR) designs It combines the latest technologies to provide enhanced safety, environmental protection, technical and economic performance above those of existing reactors. The use of a standard design provides significant benefits including taking advantage of overseas experience involving many years of design input and detailed regulatory review A plot plan (Figure 2) showing the boundary of the licensed site and a schedule of buildings and activities being undertaken therein is shown in Section 6.1 of the NSL application dossier The land that comprises the HPC nuclear licensed site falls into three landholdings and will be leased to NNB GenCo under the terms of 999 year leases The leases will give NNB GenCo exclusive possession and therefore the right to control access to the site New Nuclear Safety Cooperation Agreements will exist between NNB GenCo, Magnox Limited and EDF Energy Nuclear Generation Ltd dealing with common issues relating to access, interactions, shared services and emergency arrangements. These will take effect at the point HPC is licensed NNB GenCo will have overall control of activities at the site throughout the construction period (and beyond) supported by the AE Ancillary support activities and buildings, such as offices for management, engineering and human resources, maintenance facilities, warehouses, and storage facilities will also be onsite. A training centre/simulator and electrical substation will be built during construction phase just outside the licensed site boundary. Other temporary laydown areas, offices and a public information centre will also be constructed just outside the licensed site boundary Prior to the granting of the NSL other agreements and arrangements will be in place with EDF Energy Nuclear Generation Ltd and EDF Development Company Ltd to allow NNB GenCo to undertake preliminary works on the HPC site. Page 29 of 58

30 3.2 Basic EPR Description 123. The HPC Site will have two UK EPR s The UK EPR reactor is a PWR with a rated thermal power of 4500 MW and an electrical power output around 1630 MW depending on conventional island technology and heat sink characteristics The EPR evolutionary design is based on experience gained over many years of operation of Light Water Reactors (LWR) worldwide, primarily the most recent European PWRs (the N4 and KONVOI reactors operating in France and Germany respectively). The EPR primary system design, loop configuration, and main components are similar to those of currently operating PWRs, giving a proven foundation for the design Relative to current generation PWRs, the EPR design philosophy has the following objectives: To further reduce the likelihood of core damage; To further reduce the likelihood of large releases of radioactivity; To mitigate the consequences of severe accidents; To protect critical systems from external events; To achieve an improved plant availability factor; To give extended flexibility for different fuel cycle lengths and capability for load following; To give increased savings on uranium consumption per MWh produced; and To achieve further reduction in long-lived actinides generation per MWh through improved fuel management The EPR operating design life of 60 years, reduced fuel consumption and waste production per unit of energy output, contributes significantly to energy production from a low carbon source The following list identifies the key structures contained within the EPR unit: Reactor building used principally to house the nuclear steam-supply system; Safeguard buildings and the electrical buildings are split into four divisions, (trains) each containing a series of emergency systems with electrical support systems; Fuel building; Interim Fuel Store; Nuclear auxiliary building; Diesel-generator buildings; Effluent-treatment building; Turbine hall containing the turbo-generator, the condenser and the feedwater plant; Conventional island electrical building also known as the unclassified electrical building; Power-transmission and subsidiary feed platform; Access tower building; Page 30 of 58

31 Pumping station and the pre-discharge and discharge ponds; Operational service centre; Gas and chemical storage building; and Site waste water collecting and processing building An illustration of the completed HPC site is shown in Figure The detailed safety case for the EPR and its construction will be contained in the HPC Pre-Construction Safety Report (PCSR). 3.3 Related Permissions, Consents and Permits Funded Decommissioning Programme 131. NNB GenCo, as the prospective holder of a NSL, understands the importance of ensuring adequate funding is in place to deal with future decommissioning and waste management NNB GenCo will be submitting a FDP for HPC to the DECC for approval pursuant to Section 45 of the Energy Act The FDP will comprise the Decommissioning Waste Management Plan and Funding Arrangements Plan which are currently planned for submission to Department for Energy and Climate Change (DECC) prior to granting of the NSL The Decommissioning Waste Management Plan provides a summary of how waste and decommissioning will be managed at HPC and will set out the cost estimates, including risk and contingency The Funding Arrangements Plan will comprise a contract between NNB and an independent fund Company established for the purpose of holding the decommissioning and waste management funds remote from NNB and Government. It will set out in detail how the waste and decommissioning funds will be managed, including requirements for reporting on fund performance and the review of cost estimates and contributions to the fund An approved FDP will be in place prior to commencement of the construction phase Third Party Nuclear Liability 137. NNB GenCo has sought the approval of the DECC that the cover period under section 19 (1) of the Nuclear Installations Act (NIA) 1965 shall be effective from the date of initial receipt of nuclear fuel at HPC Generic Design Assessment 138. The HSE and the EA developed the Generic Design Assessment (GDA) process in response to a request from the Government following its 2006 Energy Review In their contributions to the Government s Energy Review, the HSE and EA set out proposals to assess new nuclear reactor designs, in advance of any site-specific proposals to build a nuclear power station. The process became known as the GDA The GDA process has been set up to improve clarity and certainty in the new nuclear power station regulatory process. It provides a structured process for early engagement between reactor designers and regulators, with HSE and EA working together. It allows safety cases for the generic new reactor designs to be assessed well ahead of any Page 31 of 58

32 construction in the UK, and for safety issues to be identified and resolved early in the project. GDA also allows the possibility of using a generic safety case as the basis for the regulation of a fleet of reactors, based on a common design, enabling EDF SA, Areva and NNB GenCo to plan with improved confidence The GDA submission comprises the Safety, Security and Environmental Report (SSER) for the proposed UK EPR design, supplemented by a number of supporting documents, providing further information in a number of areas. The SSER comprises a PCSR containing nuclear safety aspects of the UK EPR design and a Pre-Construction Environmental Report (PCER) describing the environmental impact of the reactor, including both nuclear and non-nuclear discharges and waste production. The security of the plant against deliberate malevolent acts is discussed in separate submissions which are outside the scope of these documents AREVA and EDF SA have submitted a joint application for GDA of the UK EPR. This nuclear power reactor combines familiar and proven technology with performance and safety innovations. The UK EPR is based on the EPR reactor already being built at Flamanville 3 in France A HSE Design Acceptance Confirmation (DAC) and Environment Agency Statement of Design Acceptability (SoDA) for the UK EPR are expected prior to the start of nuclear island construction Infrastructure Planning Commission 144. NNB GenCo is proposing to develop a new nuclear power station at HPC on land adjacent to the existing A and B stations. This requires an application for a development consent order to be submitted to the IPC for the main development on the site itself, as well as associated development at other locations necessary to facilitate construction and operation of the new power station. NNB GenCo have submitted a separate planning application to West Somerset Council to authorise preliminary site works at Hinkley Point and an application for a Harbour Empowerment Order to the Marine Management Organisation to authorise a temporary jetty at Hinkley Point The Planning Act 2008 imposes a duty on promoters of Nationally Significant Infrastructure Projects (NSIPs) to consult those who would be directly affected by the proposed development, people living in the vicinity of land proposed for development, the general public, local authorities and a range of other statutory consultees before submitting an application to the IPC for a Development Consent Order (DCO) NNB GenCo has almost completed the consultation process with stakeholders, the local community and the general public. For these purposes stakeholders are defined as statutory and non statutory consultees. Statutory consultees cover organisations prescribed by the IPC including, for example: the EA; Natural England; District/County and Unitary local authorities; Parish/Town Councils; and people with an interest in land proposed for development. Non-statutory bodies include a range of other relevant stakeholders at a local, regional and national level The consultation has been undertaken in two stages. Stage 1 consultation on NNB GenCo s Initial Proposals and Options for the development of HPC was carried out between November 2009 and January 2010 in accordance with a Statement of Community Consultation (SOCC) published in November Stage 2 consultation was carried out between July and October 2010 on Preferred Proposals with a Stage 2 update consultation (an update on and proposed changes to preferred proposals) being carried out between February and March Page 32 of 58

33 149. An application for a DCO will be submitted to the IPC or its successor body. It is anticipated that the assessment period for the DCO will be around 12 months and there will be interactions with IPC and its successor body throughout the period NNB GenCo will not proceed beyond preliminary works on the HPC site without receipt of the DCO Environmental Permits 151. NNB GenCo is proposing to construct, commission and operate a new nuclear power station at HPC. Activities during these project phases will require environmental permits to be granted by the EA under the Environmental Permitting (England and Wales) Regulations Some permits will be relatively limited in scope and will only affect activities undertaken in the construction phase Three permits supporting the commissioning and operation of the power station, referred to as operational permits, are being applied for early in the project lifecycle so that they can be considered in parallel with the application to the IPC for a Development Consent Order. The environmental permits do not just contain numerical limits that must not be exceeded - the fundamental permit conditions relate to the requirement for a permit holder to have suitable management arrangements, including an organisational structure and governance and sufficient competent persons and resources to operate the activities covered by the permit. The permits also require the use of best available techniques (BAT) to minimise impacts on the environment An environmental permit is required for the operation of large combustion plant - a combustion activity - such as the essential diesel generators and any associated plant which is required to provide power in the event of a loss of grid supply. The permit requires the operator to use energy efficiently, to avoid, recover and dispose of waste produced by the activities, to establish and maintain controls to minimise the risk of pollution and any emissions from the installation, to monitor emissions and to maintain and implement an Accident Management Plan. NNB GenCo is planning to make an application for a combustion activity permit The discharge of cooling water, trade effluent and treated sewage effluent to coastal waters requires a permit for a water discharge activity. The permit conditions and limits are designed to ensure the operator uses BAT to minimise impacts on the marine environment from temperature, impingement of fish and marine organisms and chemicals in cooling water discharges. NNB GenCo is planning to make an application for a water discharge activity permit Schedule 23 of the regulations is referred to as the Radioactive Substances Regulations (RSR). Under the RSR, the EA is responsible for regulating all disposals of radioactive waste from nuclear sites in England and Wales; disposal of radioactive waste includes discharges into the atmosphere, discharges into the sea, rivers, drains or groundwater, disposals to land, and disposals by transfer to another site. The RSR application and supporting documentation prepared by NNB GenCo is consistent with that required by the EA for determining an application for an environmental permit. It is in line with the UK radioactive waste strategy and proposes limits on radioactive discharges from the site that will deliver good environmental protection The EA will invite comments on environmental permit applications made by an operator after determining that the application is duly made. The applications will be placed on the public register and comments sought. The EA has a policy of increased consultation on applications at sites where they consider there is, or is likely to be a high degree of public interest. In these situations they may engage in additional consultation Page 33 of 58

34 activities including consultation on the draft permit and their decision document. Their approach is tailored to specific local circumstances For all of the environmental permits, arrangements for compliance are already or will be integrated within the NNB GenCo management system. Forward action plans and appropriate hold points in the project programme will be used to deliver effective implementation of the permit conditions over the phases of the project. 3.4 Overall Phasing 158. NNB GenCo s approach to the HPC project is to utilise best practices and to take advantage of the guidance of organisations such as the IAEA, WANO, and INPO in developing NNB GenCo standards. As discussed below, NNB GenCo is also taking advantage of the best practices of its parent Company EDF SA, who are experienced designers, constructors and operators of nuclear power plants The basic phases of the project are outlined below: Pre-Construction - NNB GenCo is currently in this phase of the project. During this phase, NNB GenCo are controlling detailed design, procurement and manufacturing of long-lead time items, and preparation of the site, including preliminary works for construction. This phase also includes a shadow working period for main safety-related construction. NNB GenCo has or is in the process of developing the requisite organisation and procedures to control such activities; Construction - This phase entails the construction and installation of safetyrelated structures, systems, and components. This phase will not commence until the NSL has been granted and other prerequisite permits, permissions and authorisations have been granted. NNB GenCo expects that the construction phase will last several years, beginning with pouring of the first safety-related concrete, and ending with the completion of pre-operational testing. Non-Active Commissioning - This phase includes inactive commissioning of safety-related systems and components and hot functional testing. Fuel delivery (i.e. the commencement of radioactive commissioning) will not take place until the appropriate non-active commissioning is complete for the structures and systems associated with fuel storage; Radioactive Commissioning - This phase begins with first fuel delivery and consists of active commissioning (e.g. testing of fuel storage systems following nuclear fuel receipt; loading of fuel in the reactor vessel, initial criticality, and power ascension testing); Operation - This phase follows the completion of radioactive commissioning and NNB GenCo s lifting of its Hold Point for Operation (described below). It includes maintenance, examination, testing, operation of the plant, and the treatment, processing, keeping, storing, accumulation or carriage of any radioactive waste; and Decommissioning - This phase consists of dismantling, decommissioning, and removal of the plant following completion of operation The phases are not necessarily distinct and are likely to overlap. For example, NNB GenCo expects that detailed design activities for some later construction activities (such as the design of low level waste storage systems) will still be ongoing during preliminary works activities related to building foundations. Similarly, NNB GenCo expects that Page 34 of 58

35 systems and areas will be handed over from the constructor to the testing organisation at different times, such that some systems will be undergoing non-active commissioning while the construction of other systems will be ongoing. In addition, construction of the two Hinkley Point units will be staggered, such that the first unit is expected to become operational while the second unit is still undergoing construction and commissioning The overall programme for the construction at HPC, including the preliminary works incorporates: The site preparation works; Construction and subsequent operation of the temporary jetty; Construction of the on-site accommodation campus; Construction of HPC, including the nuclear island, conventional island, the balance of plant, ancillary buildings and structure, the National Grid 400kV substation and overhead line transmission infrastructure; Construction of the Interim Fuel Store; Construction of the cooling water infrastructure; Dismantling and removal of the temporary jetty; Removal of the on-site accommodation campus; and Landscape restoration Hinkley Point C Hold Points 162. NNB have set hold points to ensure ordered and sequential progress between defined steps in the programme and that they are managed in a safe, cost effective and controlled manner. NNB GenCo recognise that HSE or EA may select any of the identified hold points for formal regulatory hold points or impose additional ones within their powers The NNB GenCo process for defining, managing and releasing these hold points is described in Ref 17, including the management of ONR & EA permissions NNB GenCo have defined a set of primary hold points outlined below: NNB GenCo taking control of the HPC site; DCO Application; Final Investment Decision; First Safety Concrete; Nuclear Island Concrete; Non-Active Commissioning; Active Commissioning; First Criticality; and Rating Certificate It should be noted that the Hold Point List will develop and change as the project progresses Each of the specific hold points will have a set of specified assessment criteria to determine whether permission should be granted by NNB GenCo to release the hold Page 35 of 58

36 point and proceed with the work. These criteria are determined by the nature of the operation to be performed and the risks associated with it. They may be related to the organisation, procedures, competency & training, safety case documentation, availability of systems, or to the maturity of key elements of the design In addition to these proposed primary NNB GenCo hold points, NNB GenCo have set secondary and tertiary hold points to ensure that work does not proceed until specified pre-requisites and approvals have been satisfied. 3.5 HPC Site Organisation 168. The HPC Construction Director has full responsibility for the HPC Site and activities during construction and up until handover to the Pre-Operations Director The key responsibilities of the HPC Construction Director during the Pre-Construction phase are: Pre-construction planning for the construction phase; Creating and maintaining a culture of construction excellence including all aspects of safety, environmental management and security on the HPC site; and Establishing and maintaining a site organisation to deliver the project and satisfy nuclear site licensing and environmental permitting requirements The detailed construction organisation is currently being developed based on reviews of industry best practice. This will be covered in a revised MP and NB prior to construction The functions that will report through to the HPC Construction Director include: Off-site Construction; Nuclear, Environmental and Site Controls; Construction Support; Site Engineering; Commissioning; Construction Safety; o Industrial safety inspection and advice. HR, Business and Site Support; o Security; o Construction Training; and o Organisational Learning for Construction Key interfaces between the HPC site and central NNB GenCo functions are with: Safety Directorate for oversight; Design Authority (supplying accepted designs to the site teams and the modifications process); Project Management; Project Controls; and Procurement. Page 36 of 58

37 173. During the construction phase, the intent is that the design will be received by the Construction Support Team as accepted by the NNB GenCo DA. The design packages will be supplied to the HPC Construction Team for the build It should be noted that prior to SZC construction commencing, the impact on the HPC Organisation (and its support from NNB GenCo, and EDF SA as the AE and RD) will be assessed to ensure appropriate resources are available. Page 37 of 58

38 4 MANAGEMENT SYSTEM 4.1 Background 175. The NNB GenCo management system defines the processes, procedures, measurement, assessment and continual improvement techniques, management responsibilities and commitment, line organisation and the main interfaces between NNB GenCo, EDF Energy and others. The management system integrates safety, health, environmental, security, and quality requirements This document describes NNB GenCo management system processes and procedures to be implemented through a prioritised work plan as well as the measurement, assessment and continual improvement techniques to be implemented The NNB GenCo Integrated Management System (IMS) is guided by current standards including: The IAEA Safety Requirements No. GS-R-3, The Management System for Facilities and Activities ; International Organisation for Standardization (ISO) BS EN ISO 9001:2008; BS EN ISO 14001:2004; BS OHSAS 18001:2007; and BS EN ISO/IEC 27001: The management system manual applies to all phases of the project life cycle and for the entire duration of activities The management system manual will be regularly reviewed including before the beginning of each phase to ensure the requirements of that phase will be met The full management system is presented in the Management System Manual [Ref 18], a summary is presented herein relevant to the MP Compliance Matrices have been developed on how the NSL conditions translate into the NNB Management System for current and future phases of work. These are contained in section 4,1 of the licence application dossier. 4.2 Process Categories 182. Process categories define the processes that exist within the framework as being core, management or support processes: Management Processes drive, govern and assure all other processes within the framework; Core Processes deliver the organisations key products and services and are typically expressed as a value chain, taking an input and transforming it into a value adding output; and Support Processes are enablers for the core and management processes Figure 7 shows the document hierarchy within the IMS and the relationship between strategy, policy, process, procedure, and the tools and standards 184. Figure 8 below shows Process Groups. Page 38 of 58

39 4.3 Management Processes 185. The management processes are the process capabilities that give direction and assurance on the core and support processes. The NNB GenCo Management Processes are: Business Planning & Investment 186. Process Group Objective: To define the vision, ambition and values of NNB GenCo as well as the strategic objectives aligned to EDF Energy. To provide financial forecasts for the business programme and to monitor performance against the objectives and forecasts Process Group Description & Scope: To define the strategic objectives and establish the medium and long term business plans, financial budgets and forecasts based on the EDF Energy medium term plan. To monitor the performance of NNB GenCo against its objectives, budgets and forecasts and to ensure the availability of financial resources to meet NNB GenCo business objectives Governance 188. Process Group Objective: To embed an integrated governance framework covering the decision-making, performance management and control of NNB GenCo; providing the structures to give overall direction to the organisation and to satisfy expectations of accountability to those outside it and ensuring that safety and risk management is at the heart of decision-making and is considered and supported at the highest level of NNB GenCo Process Group Description & Scope: To define and document the policies, processes, procedures, controls and accountabilities for decision-making within NNB GenCo. To ensure that risks are effectively mitigated and robust controls are established. To provide legal counsel to ensure that NNB GenCo complies with all relevant legislation, policies and procedures Assurance 190. Process Group Objective: To provide confidence that technical, health & safety, quality, nuclear, environmental and security requirements are complied with Process Group Description & Scope: To perform business, technical and regulatory assurance activities and to address non-conformances Process Capability scope includes: Perform Design Assurance to ensure the safety and technical suitability of design deliverables through observation and surveillance activities; Technical Assurance to ensure that the technical integrity of a product, process or system is monitored and maintained; Perform Independent Assessment, Challenge & Oversight to assess the activities performed by NNB GenCo through internal or external audits, reviews and inspections; Assess Internal Controls to ensure that the internal controls for NNB GenCo are delivered through the organisation s structure, governance arrangements, systems, processes and procedures, and that the effectiveness of the controls are monitored and reported; Page 39 of 58

40 Assess Compliance to assess compliance against requirements including Nuclear Site Licence, health, safety, environment, quality and security. This can be conducted through documentation reviews, inspections and surveillance; and Manage Non-Conformance to identify and report products and processes that do not conform to specified requirements with the identified Non- Conformances segregated, recorded, reviewed, categorised and analysed Continuous Improvement 193. Process Group Objective: To provide a Continual Performance Improvement framework that enables the organisation to learn and improve Process Group Description & Scope: To establish and maintain a framework of tools, methodologies and supporting arrangements to enable business areas and process owners to identify, prioritise and deliver sustainable performance improvement Process Capability scope includes: Enable Organisational Learning to facilitate continuous improvement whilst supporting a healthy safety culture. It relies on report of internal events, and knowledge gained from external events, to allow the promotion of good practice and assist personnel to avoid errors and bad practice. It incorporates the Corrective Action Programme (CAP) and Operating Experience (OPEX); Improve Process Performance to understand and improve process performance including the Self Assessment of organisational teams and processes, and the Management Review of the Integrated Management System; and Manage Knowledge to provide a range of strategies and practices used by NNB GenCo to identify, create, represent, distribute, and enable adoption of insights and experiences. Such insights and experiences comprise knowledge, either embodied in individuals or embedded in organisational processes or practices. 4.4 Support Processes 196. The support processes are the process capabilities that enable the core and management processes to function. The NNB GenCo support processes are as follows: Documents and Records 197. Process Group Objective: To deliver and maintain a coherent and co-ordinated approach to Document and Records Management throughout NNB GenCo, to ensure consistency of approach, effectiveness in operations, compliance with regulations, and to meet commercial objectives, whilst protecting information and access to it Process Group Description & Scope: To manage documents and records produced and received by NNB GenCo, meeting Civil Nuclear Security (CNS), NSL and RSR requirements for the collaboration of information and the management of nuclear lifetime records Process Capability scope includes: Page 40 of 58

41 Manage Documents Originated by NNB GenCo; Manage Documents Received by NNB GenCo; Review Documents, Records & Physical Samples; Store Physical Samples; and Dispose of Records Human Resources 200. Process Group Objective: To recruit, develop and retain competent and motivated employees and to ensure that the organisation has the right number of employees during to prepare resource requirements each stage of the project lifecycle Process Group Description & Scope: To handle potential and actual employees and to ensure that changes in the organisation are managed appropriately and in accordance with statutory, regulatory and licensing requirements Process Capability scope includes: Plan Resources succession planning, workforce risk assessment and the design of the organisation; Recruit Staff; Manage Performance; Manage Employee Engagement; Manage Leavers; Manage Organisational Change to control organisational changes and manage the potential impacts organisational changes will have on nuclear and radiological safety, environmental protection relating to radioactive substances and the security aspects where they impact on nuclear safety either immediately or due to latent effects which could have an impact in the future; and Manage employee relations Competence and Training 203. Process Group Objective: To ensure that individuals receive the appropriate training to develop the competencies needed to perform their assigned roles Process Group Description & Scope: Applies to all NNB GenCo staff and contracted and non-plant personnel through the pre-construction, construction and operating phases. Training, experience and educational requirements associated with each designated role are established, as well as the process for assessing individuals against these requirements. Appropriate training is identified, produced and delivered using a systematic approach Process Capability scope includes: Manage Competency to identify the competency requirements for specified roles and compare the requirements with the individuals nominated for these roles, identifying any shortfalls and making plans to address them; Analyse Training Need; Design Training; Page 41 of 58

42 Develop Training; Implement Training; and Evaluate Training; External Communications 206. Process Group Objective: To ensure NNB GenCo strategy, objectives and message is positively received by external stakeholders and to recognise the relationship with EDF Energy for external communication Process Group Description & Scope: To manage external communication Finance 208. Process Group Objective: To provide financial accounting services and manage the interface with EDF Energy Shared Service teams Process Group Description & Scope: To provide financial accounting support, to manage the payroll and to prepare periodic reporting to EDF Energy Information Management 210. Process Group Objective: To provide Information Systems (IS) which are capable of providing and managing the information required to effectively manage the organisation Process Group Description & Scope: The planning, acquisition, implementation, monitoring, evaluation, delivery and support of the IS services used to manage NNB GenCo information Properties and Facilities 212. Process Group Objective: To provide property and facilities services that satisfy both internal and external (regulatory) stakeholders Process Group Description & Scope: The provision of property and facilities management services at designated NNB GenCo sites Health, Safety, Environment and Security 214. Process Group Objective: To ensure the safety of the public and the workforce, minimise impacts on the environment during the life cycle of the plant, maintain effective security arrangements and provide arrangements for dealing with emergency situations Process Group Description & Scope: To manage personnel, physical and information security to protect NNB GenCo assets, premises and people. To ensure that robust arrangements are in place for performing work in a safe manner and that incidents and emergencies can be handled appropriately Process Capability scope includes: Manage Personnel Security to manage the risk of people maliciously exploiting legitimate access to NNB GenCo assets or premises for unauthorised purposes. This also includes the identification and mitigation of threats to individuals and assets held by them when outside NNB GenCo sites; Manage Physical Security to deter, prevent, detect, delay, assess and respond to any attempts at unauthorised physical access to protected sites or assets held on sites; Page 42 of 58

43 Manage Information Security to protect the availability, integrity and confidentiality of NNB GenCo information assets; Manage Occupational Health & Industrial Safety to ensure that activities undertaken by NNB GenCo and its contractors are performed safely through permits for work, point of work risk assessments, use of equipment, first aid arrangements etc and to manage any occupational health & industrial safety incidents that may occur; Manage Environment & Waste to ensure that activities undertaken by NNB GenCo and its contractors are performed with due care for the environment and to deliver effective environmental performance by the production, issue and update of environmental management & monitoring plans, by the management of any radioactive and non-radioactive waste that is generated during business activities and by the management of any environmental incidents that may occur; and Manage Emergency Arrangements to define, implement, test and maintain the relevant emergency response arrangements that are to be followed in the event of abnormal situations or an emergency on an NNB GenCo site. 4.5 Core Processes 217. The core processes are the process capabilities that deliver the organisation s products and services. Core Processes include: Project Management 218. Process Group Objective: To manage the UK EPR Programme through the preconstruction, construction, non-active commissioning, radioactive commissioning, operation and de-commissioning phases, within the constraints of Safety, time, cost and quality requirements Process Group Description & Scope: To plan, organise, secure and manage the resources required to successfully complete the UK EPR Programme Design 220. Process Group Objective: To provide and maintain a UK and site-specific EPR design aligned to the regulatory requirements for a new nuclear power plant Process Group Description & Scope: To manage the interface with the GDA process and the subsequent adaptation of detailed design to meet UK and site specific requirements, ensuring compliance with regulatory controls Process Capability scope includes: Capture Requirements for Design to identify and document design requirements in technical specifications and to produce the safety and environment cases; Produce Design to translate specified requirements into design outputs. ensuring compliance with UK regulations; Verify Design to ensure design meets requirements and verification is carried out based on the complexity, uniqueness or hazards associated with the design; Page 43 of 58

44 4.5.3 Procure Accept Design to formally accept the design and to obtain regulatory approval to the UK and site-specific designs; and Manage Design Change to ensure proposed changes to the design are documented, reviewed and approved, and to also ensure that the safety and environment cases are updated throughout the lifecycle of the plant Process Group Objective: To procure the goods and services that meet quality and nuclear safety requirements for the design, construction, operation and decommissioning of the nuclear plants Process Group Description & Scope: To manage all the activities in support of the procurement of goods and services for the construction of nuclear plants Process Capability scope includes: Create Procurement Strategy & Governance Model; Hold Package Kick-Off; Source Suppliers; Pre-Qualify Suppliers; Issue Invitation to Tender; Evaluate Tender; Manage Preferred Bidders Negotiation & Selection; and Award Contract Manufacture 226. Process Group Objective: To supply components and equipment in accordance with specified requirements Process Group Description & Scope: to provide assurance of the correct application of contractual arrangements and the conformity of components and equipment with specified requirements Process Capability scope includes: 229. Conduct Manufacturing Surveillance a graded approach, dependent on criticality of the component/equipment, to ensure Contractors, Manufacturers, Suppliers and Sub- Contractors activities are carried out, and the supplies and services are produced, to the required level of quality Construct 230. Process Group Description & Scope: To manage the construction programme and discharge the responsibilities of the Intelligent Customer in relation to the AE Process Capability scope includes: Manage Site to manage on-site logistics and facilities, induction of personnel, document control and site communication; Handover to Site to manage the handover of design, equipment, schedule, permits etc from their originators to the construction site; Page 44 of 58

45 Manage Interface with Contractors to manage the interface between NNB GenCo and contractors, and also the interface and hand-offs between contractors e.g. civil to mechanical & electrical; Manage Construction to supervise construction activity, handle site nonconformances, capture the as built design and to approve handover from the contractor; Manage Construction Change; Handover to Commissioning; and Dismantle Temporary Structures Commission 232. Process Group Objective: To verify the structures, systems and component functions are in accordance with the design intent prior to the issue of the plant operation rating certificate Process Group Description & Scope: The process during which nuclear power plant structures, systems and components, having been constructed, are made operational and verified to be in accordance with the design and to have met the required performance criteria Process Capability scope includes: Prepare for Commissioning to prepare test plans including test stages, identify test equipment and resources, and document, review and approve test procedures; Conduct Commissioning to execute tests as planned with regulatory inspections in line with agreed hold points and monitor\report test progress; Verify Commissioning to analyse test results and verify the tests have been properly completed; and Handover to Operations to compile the test procedures and all related documentation for handover to operations Operate 235. Process Group Objective: To ensure the safe, reliable and efficient running of the station Process Group Description & Scope: All activities required to operate and maintain the plant, ensuring the plant operates safely, reliably, efficiently with optimised performance and scheduled maintenance Decommission 237. Process Group Objective: To plan for the decommissioning of a nuclear plant at the end of a plant s productive lifecycle in accordance with statutory requirements Process Group Description & Scope: To manage the preparation of a corporate decommissioning strategy to comply with statutory, regulatory and licensing requirements and ensure that NNB GenCo is able to meet the full cost of decommissioning its nuclear plants and meet its share of waste management costs Process Capability scope includes: Page 45 of 58

46 Prepare Decommissioning Plans to include a group level strategy covering all plants, with proposals for waste disposal, decommissioning, estimates of costs and specification of the financial securities that apply Consents, Permits and Licences 240. Process Group Objective: To satisfy external planning requirements for obtaining development consent orders, and to obtain a NSL and environmental permits, and meet all legal requirements during the life of the build Process Group Description & Scope: To manage the lifecycle of the application from identification of the required consents, permits and licences through to managing changes for consents, permits and licences that have been granted Process Capability scope includes: Manage Pre-Application Activity; Prepare Application; Obtain Consents, Permits & Licences; and Change Consents, Permits & Licences. Page 46 of 58

47 5 ORGANISATIONAL CAPABILITY 5.1 Nuclear Baseline 243. The Nuclear Baseline (NB) is an integral part of the arrangements that demonstrate that NNB GenCo is an intelligent operator, a capable licensee and holder of environmental permits and consents. It shows that it has the organisation, resource and competences needed for this Pre-Construction phase and is preparing for the capability challenges of the future. The NB is owned by the HR Director NNB GenCo recognises the importance of the NB throughout the lifecycle of the project and has developed an approach that draws on best practice and reflects regulatory and industry guidance The NB has a number of purposes: To demonstrate that NNB GenCo, as the holder of the NSL and Environmental Permits and Consents, has suitable and sufficient organisational structures, resources and competence to be able to reliably and effectively carry out all activities that may impact on nuclear safety; To describe responsibilities to adequately manage the design supply chain and ensure adequate technical competences to oversee the nuclear safety related activities are available at the right time in the lifecycle; To support the development of the IC capability for the oversight of nuclear safety related activities undertaken on its behalf by others; As an ongoing management tool to provide a reference point for the assessment of change; Provide evidence that NNB GenCo is in control of activities through the right allocation of responsibilities for all work that has the potential to impact on nuclear safety; Demonstrate how nuclear responsibilities for safety, environment and security are allocated across the organisation to achieve legal compliance; and Provide an overview of the staffing levels for this Pre-Construction phase and a look ahead to the future Like the MP, the NB will be updated at appropriate intervals to take account of changes to the organisation The NB also identifies vulnerabilities and the associated mitigation The NB provides the detailed roles, capability and posts to support the MP for NNB GenCo as an NSL and Environmental permit holder. 5.2 Control of Organisational Change 249. NNB GenCo recognises the importance of identifying and managing organisational change. Page 47 of 58

48 250. NNB GenCo has produced and are currently implementing robust arrangements which apply from top to bottom in the organisation and will have an appropriate organisation in place to support it under the HR Director These arrangements include: Identification of what constitutes an organisational change; Description and categorisation of organisational change based on the potential impact on the NNB GenCo NB (impact on roles/posts/ic status); Assessment, planning and success criteria of the organisational change; Consideration and Approval of the change through an NNB GenCo Management of Change Committee chaired by the HR Director; and Post implementation assessment of the change and close out The arrangements once implemented will consider the cumulative effect of changes on the organisation and identify any mitigation necessary Applying organisational change in this way will ensure changes are fully assessed to ensure NNB GenCo remains a competent licensee, justified and the NB is appropriately maintained by keeping a record of organisational changes. 5.3 Design Authority 254. The DA reports through to the Project Director HPC The DA is responsible for reviewing and accepting the design of the UK EPR, the control of modifications process and the development of the safety cases. The DA provides an integrated design authority capability calling on expertise within itself or through others in the NNB GenCo such as the Environment team EDF SA has a large, existing organisation and capability to support the design, engineering and safety case of the UK EPR. NNB GenCo will appoint EDF SA as the AE and RD, and ensure the requirements of HSE guidance on the design authority [Ref 6] are met The NNB GenCo DA already has IC capability in place for the RD relationship for the current lifecycle. This will continue to be reviewed and increase as the organisation and project develops The NNB GenCo DA has responsibility for the production and ownership of safety and environmental documentation for HPC. Production of safety documentation for HPC will be managed by the DA, supported by EDF SA Independent Technical Assessment (ITA) of safety documentation will be undertaken by the DA team with external support from other parts of the business and contract expertise if necessary. As the project evolves, NNB GenCo will increase its involvement in producing safety submissions. As the DA becomes more involved in production of such documents it may become harder to ensure a reasonable level of independence between production / review and ITA inside the same entity. ITA of safety documentation for commissioning (and beyond) will be undertaken by a different team located within the Safety Directorate with support from within the business where appropriate NNB GenCo through the DA, has sufficient capability and knowledge of the reactor design, safety and environment case for the current phase. This capability, knowledge and ownership will grow through recruitment and through experience in the lifecycle of Page 48 of 58

49 the project through design, construction, commissioning and operation, and working with EDF SA. 5.4 Organisational Learning 261. Responsibility for Organisational Learning rests with the Safety Director Organisational learning is accepted by NNB GenCo as an integral, key part of a successful nuclear safety culture and management system. It is a combination of the processes to facilitate learning and the attitudes and behaviours of individuals and of the organisation A suitable arrangement and organisation are in place proportionate to the Pre- Construction phase of the project including: Identification of Operational Experience (OPEX) and ensure due consideration by the NNB GenCo Board and Committees; Procedure and Training for Organisational Learning (Including incident management, reporting, investigation and corrective action); Operational experience from learning reports, analysis and communications plans in place for sharing experience and learning (along with any recommendations therein); and Established NNB GenCo links to national and international learning forums Organisational Learning in NNB GenCo covers safety, environment, health and security NNB GenCo will identify, communicate and where appropriate, make recommendations and implement them to ensure lessons are learnt NNB GenCo will review and update the arrangements for Organisational Learning as the project and organisation progresses through the phases of construction, commissioning, operation and decommissioning. 5.5 Knowledge Management 267. Knowledge Management (KM) is an important part of the NNB GenCo approach to developing the organisation and closely linked to Organisational Learning and Safety Culture. NNB GenCo is building the knowledge to be able to be in control of design, construction, commissioning and ultimately operation. NNB GenCo s approach on Knowledge Management is to: Develop the overall KM process for NNB GenCo; Identify the KM needs of the organisation; Implement the process for the receipt, storage, management and preservation of knowledge within NNB GenCo; and Set up the process for disseminating information and knowledge throughout NNB GenCo, suppliers and contractors This approach on KM is being applied initially in the NNB GenCo DA and then across the Company. Responsibility for knowledge management rests with the Project Director HPC. Page 49 of 58

50 5.6 Intelligent Customer Capability 269. NNB GenCo recognises the importance of being an IC for any services it procures or receives. This is particularly so given the key AE and RD relationship with EDF SA. Responsibility for IC rests with the Project Director HPC 270. NNB GenCo s approach to IC applied through the procurement procedures follows six basic steps: Make or Buy decision; Defining the nuclear safety significance of the work; Specifying the work; Assessing and selecting the contractor; Oversight of work in progress; and Accepting completed work This will be applied throughout the business in areas such as: Procurement and Contract Management; Design review and acceptance, Design Change; Non conformance and manufacturing surveillance; Construction surveillance and field changes; and Plant acceptance and handover Safety and Environmental IC roles within the NNB GenCo organisation are specifically identified within the NB. Role and training profiles will be fully implemented (prior to NSL granting) for those IC roles to ensure capability across the organisation and ensure it is appropriately applied. Page 50 of 58

51 6 FORWARD WORK PLAN 273. This MP and the associated NB explain the Company structure, processes and capability required and show how safety, security and environmental protection are managed within NNB GenCo The MP and NB will be revised in line with the Forward Work Plan (FWP) [Ref 19] to ensure they are kept up to date As the Hinkley Point C organisation progresses, the MP will then be updated in line with the FWP to reflect the organisation, its activities through construction, commissioning and operation. The next update will be prior to granting of the NSL Updating the MP in this way will ensure that the development of the organisation and its systems is appropriate and that the MP remains a live document for the management of the safety, security, quality and environmental aspects of the Company s operations The FWP also describes when the procedures, arrangements and organisation will be reviewed or changed going forward up to operation. Page 51 of 58

52 7 CONCLUSION 278. The (MP) demonstrates that NNB GenCo is a capable and competent applicant for a Nuclear Site Licence (NSL) and operational environmental permits for Hinkley Point C. In producing the NNB GenCo MP the following key documents were considered: Function and content of a safety management prospectus (HSE internal guidance T/AST/072 Issue 1); Guidance on the Production and Use of an Integrated Guidance Note Radioactive Substances Regulation HSE and Environment Agency; The licensing of nuclear installations, HSE; HSE NSD Safety Assessment Principles for Nuclear Facilities 2006 Edition, Revision 1; Radioactive Substances Regulation: Management Arrangements at Nuclear Sites - Version 2 - Environment Agency; Radioactive Substances Regulation - Environmental Principles - Version 2 - Environment Agency The MP describes the organisational structure, governance and approach to ensuring the delivery of Safety within NNB GenCo. This MP forms part of the NSL application dossier and RSR permit application. Page 52 of 58

53 APPENDIX A FIGURES Figure 1: Corporate Structure, ownership and HPC land leases to NNB GenCo Page 53 of 58

54 Figure 2: Hinkley Point C Proposed Nuclear Licensed Site Boundary (solid red line) Figure 3: Illustrative view of the Hinkley Point C site Page 54 of 58

55 Figure 4: NNB GenCo Board Figure 5: NNB GenCo Executive Team Page 55 of 58

56 Figure 6: Board Committees Vision S Mission Strategy Values, Expectations Company Manual Policies & Standards Policies describe the internal &external standards applied by NNB GenCo Management System Manual Processes Processes describe a set of interrelated or interacting activities which transform inputs into outputs. Processes capture the why, what, who, controls, risks &metrics associated with the activities Procedures Procedures describe the how, setting out the specific way in which activity steps are carried out. Systems, Tools & Work Instructions Figure 7: NNB GenCo Management System Hierarchy Page 56 of 58

57 Figure 8: NNB GenCo Process Groups Page 57 of 58

58 NNB GenCo Company Document NNB-OSL-REP APPENDIX B NNB GENCO HEALTH, SAFETY, ENVIRONMENT AND QUALITY POLICY Page 58 of 58