Radioactive Substances Regulation Permit Management Prospectus

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.
NNB GenCo – Company Document NNB-OSL-REP-000054
Management Prospectus
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MANAGING DIRECTOR’S STATEMENT

This Management Prospectus 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 Management Prospectus 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 Management Prospectus 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
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TABLE OF CONTENTS
1 INTRODUCTION ....................................................................................................................8
1.1 References and Definitions ........................................................................................... 11
2 NNB GENCO........................................................................................................................14
2.1 The Company.................................................................................................................. 14
2.1.1 NNB GenCo.................................................................................................................. 14
2.1.2 NNB GenCo Vision and Values..................................................................................... 14
2.1.3 Organisation of NNB GenCo......................................................................................... 15
2.2 The Role of the Architect Engineer and Responsible Designer.................................. 15
2.2.1 Architect Engineer......................................................................................................... 16
2.2.2 Responsible Designer................................................................................................... 17
2.3 The NNB GenCo Board .................................................................................................. 17
2.3.1 Responsibilities............................................................................................................. 17
2.3.2 Governance, Risk Management and Internal Control.................................................... 17
2.3.3 Safety Governance ....................................................................................................... 18
2.3.4 Operations .................................................................................................................... 18
2.4 Membership of the Board .............................................................................................. 19
2.4.1 Managing Director......................................................................................................... 20
2.4.2 Project Director HPC..................................................................................................... 20
2.4.3 Client Construction Director .......................................................................................... 22
2.4.4 EPR Architect Director .................................................................................................. 22
2.4.5 Planning and External Affairs Director........................................................................... 22
2.4.6 Finance Director ........................................................................................................... 23
2.4.7 Human Resources Director........................................................................................... 23
2.4.8 Non Executive Directors ............................................................................................... 23
2.4.9 Company Secretary ...................................................................................................... 24
2.5 NNB GenCo Executive ................................................................................................... 24
2.5.1 Responsibilities of the Executive................................................................................... 24
2.5.2 Membership of the Executive........................................................................................ 24
2.5.3 Safety Director.............................................................................................................. 25
2.5.4 HPC Site Construction Director..................................................................................... 25
2.5.5 Pre-Operations Director ................................................................................................ 25
2.6 Committees..................................................................................................................... 26
2.6.1 Safety, Health and Environment Committee.................................................................. 26
2.6.2 Nuclear Safety Committee ............................................................................................ 26
2.6.3 Construction Committee ............................................................................................... 27
2.6.4 Operational Control Committee..................................................................................... 27
2.6.5 The Investment Committee ........................................................................................... 28
3 THE UK EPR FOR HINKLEY POINT C................................................................................29

3.1 The Hinkley Point C Site ................................................................................................ 29
3.2 Basic EPR Description................................................................................................... 30
3.3 Related Permissions, Consents and Permits ............................................................... 31
3.3.1 Funded Decommissioning Programme ......................................................................... 31
3.3.2 Third Party Nuclear Liability .......................................................................................... 31
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3.3.3 Generic Design Assessment ........................................................................................ 31

3.3.4 Infrastructure Planning Commission ............................................................................. 32
3.3.5 Environmental Permits ................................................................................................. 33
3.4 Overall Phasing.............................................................................................................. 34
3.4.1 Hinkley Point C Hold Points.......................................................................................... 35
3.5 HPC Site Organisation................................................................................................... 36
4 MANAGEMENT SYSTEM.................................................................................................... 38
4.1 Background.................................................................................................................... 38
4.2 Process Categories ....................................................................................................... 38
4.3 Management Processes ................................................................................................ 39
4.3.1 Business Planning & Investment .................................................................................. 39
4.3.2 Governance.................................................................................................................. 39
4.3.3 Assurance .................................................................................................................... 39
4.3.4 Continuous Improvement ............................................................................................. 40
4.4 Support Processes ........................................................................................................ 40
4.4.1 Documents and Records .............................................................................................. 40
4.4.2 Human Resources........................................................................................................ 41
4.4.3 Competence and Training ............................................................................................ 41
4.4.4 External Communications............................................................................................. 42
4.4.5 Finance ........................................................................................................................ 42
4.4.6 Information Management.............................................................................................. 42
4.4.7 Properties and Facilities ............................................................................................... 42
4.4.8 Health, Safety, Environment and Security .................................................................... 42
4.5 Core Processes.............................................................................................................. 43
4.5.1 Project Management .................................................................................................... 43
4.5.2 Design.......................................................................................................................... 43
4.5.3 Procure......................................................................................................................... 44
4.5.4 Manufacture ................................................................................................................. 44
4.5.5 Construct...................................................................................................................... 44
4.5.6 Commission ................................................................................................................. 45
4.5.7 Operate ........................................................................................................................ 45
4.5.8 Decommission.............................................................................................................. 45
4.5.9 Consents, Permits and Licences .................................................................................. 46
5 ORGANISATIONAL CAPABILITY....................................................................................... 47
5.1 Nuclear Baseline ............................................................................................................ 47
5.2 Control of Organisational Change ................................................................................ 47
5.3 Design Authority ............................................................................................................ 48
5.4 Organisational Learning................................................................................................ 49
5.5 Knowledge Management ............................................................................................... 49
5.6 Intelligent Customer Capability .................................................................................... 50
6 FORWARD WORK PLAN.................................................................................................... 51
7 CONCLUSION ..................................................................................................................... 52
APPENDIX A FIGURES .......................................................................................................... 53
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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
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1 INTRODUCTION
1. This Management Prospectus (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 2009. 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.
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7. The MP and NB consider the early activities NNB GenCo will undertake during the pre-
construction 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.
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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.
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1.1 References and Definitions

Ref Title Location Document No.
1 NNB GenCo Nuclear Baseline v2 EDRMS NNB-HRE-ASS-000001
HSE – NSD Safety Assessment Principles for HSE Website http://www.hse.gov.uk/nu

2
nuclear facilities, 2006. clear/saps/
Function and content of a safety management HSE Website http://www.hse.gov.uk/foi

3 prospectus (HSE internal guidance T/AST/072 – /internalops/nsd/tech_as
Issue 1). st_guides/tast072.htm
HSE Website http://www.hse.gov.uk/nu

4 The licensing of nuclear installations clear/notesforapplicants.
pdf
HSE Website http://www.hse.gov.uk/foi

HSE – The processing of licence applications for
5 /internalops/nsd/inspectio
new nuclear sites, INS/036 Issue 1.
n/ins036.htm
Licensee design authority capability HSE Website http://www.hse.gov.uk/foi

6 T/AST/079 – Issue 1 – HSE /internalops/nsd/tech_as
st_guides/tast079.htm
HSE Website http://www.hse.gov.uk/foi

Procurement of nuclear safety related items or
7 /internalops/nsd/tech_as
services T/AST/077 – HSE
Licensee use of contractors and intelligent HSE Website

customer capability http://www.hse.gov.uk/foi
8 /internalops/nsd/tech_as
T/AST/049 – Issue 3 – HSE
EA Website http://www.environment-
Radioactive Substances Regulation:
agency.gov.uk/static/doc
9 Management Arrangements at Nuclear Sites –
uments/Business/GEHO
Version 2 – Environment Agency
0709BQXB-E-E.pdf
Radioactive Substances Regulation –
10 Environmental Principles, The Environment
uments/Business/GEHO
Agency Version 2.0
0709BQXB-E-E.pdf
Guidance on the Production and Use of an
Integrated Management Prospectus – Guidance
11 uments/Business/GEHO
Note – Radioactive Substances Regulation –
0709BQWX-E-
HSE and Environment Agency.
E_(2)_(2).pdf
Nuclear New Build (GenCo) Resourcing Strategy Held by NNB GenCo Held on NNB GenCo
12
– Issue 1, January 2010 HR system.
13 NNB GenCo Company Manual EDRMS NNB-OSL-MAN-000002
Application for a Nuclear Site Licence for Hinkley EDRMS

14 Point C - Head Document NNB-OSL-REP-000065
15 Internal Challenge and Oversight Strategy EDRMS NNB-OSL-STR-000007
Terms of reference and membership of the NNB EDRMS

16 NNB-OSL-TOR-000003
Nuclear Safety Committee.
NNB GenCo Company Procedure – Define, EDRMS

17 NNB-OSL-PRO-000012
Manage and Release Key Hold Points.
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Ref Title Location Document No.
18 NNB GenCo Management System Manual EDRMS NNB-OSL-MAN-000004
Forward Work Plan for Hinkley Point C Nuclear EDRMS

19 NNB-OSL-PLN-006006
Site Licence Application
Term / Abbreviation Definition

AE Architect Engineer
AGR Advanced Gas-Cooled Reactor
BAT Best Available Technique
BS British Standard
CAP Corrective Action Plan
CNS Civil Nuclear Security
DA Design Authority
DAC Design Acceptance Confirmation
DCO Development Consent Order
DECC Department of Energy and Climate Change
DIN Division Ingénierie Nucléaire, The engineering division of EDF SA
EA Environment Agency
From 1 July 2011, EDF Energy Nuclear Generation Limited, Company Number 03076445
EDF Energy Nuclear Generation
whose registered office is at Barnett Way, Barnwood, Gloucester, GL4 3RS, formerly known
Ltd
as British Energy Generation Limited (BEGL).
EDF SA Electricité de France Société Anonyme
EDRMS Electronic Document and Record Management System
EPR The Pressurised Water Reactor developed and trademarked by AREVA
FDP Funded Decommissioning Programme
FWP Forward Work Plan
GDA Generic Design Assessment
HPA Hinkley Point ‘A’
HPB Hinkley Point ‘B’
HPC Hinkley Point ‘C’
HR Human Resource
HSE Health and Safety Executive
IACO Independent Assessment, Challenge and Oversight
IAEA International Atomic Energy Agency
IC Intelligent Customer
IEC International Electro-Technical Commission
IMS Integrated Management System
INPO Institute of Nuclear Power Operators
IPC Infrastructure Planning Commission
IS Information System
ISO International Organisation for Standardisation
ITA Independent Technical Assessment
KM Knowledge Management
KPI Key Perform ance Indicator
LWR Light Water Reactor
MD Managing Director
MP Management Prospectus
MWh Mega-Watt Hour
NB Nuclear Baseline
NDA Nuclear Decommissioning Authority
NIA Nuclear Installations Act (1965) as Amended
NNB GenCo NNB Generation Company Limited
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Term / Abbreviation Definition

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

2.1.1 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 06937084 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 1.
23. 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.
2.1.2 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.
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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.
2.1.3 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.
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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.
2.2.1 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
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which describe the requirements from both EDF SA and NNB GenCo for particular
aspects.
2.2.2 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

2.3.1 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:
2.3.2 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;
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• 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.
2.3.3 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.
2.3.4 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;
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• 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.
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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.
2.4.1 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.
2.4.2 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:
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• 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.
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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.
2.4.4 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.
2.4.5 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).
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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).
2.4.7 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.
2.4.8 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.
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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

2.5.1 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.
2.5.2 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;
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• HR Director; and
• Company Secretary.
90. Responsibilities of the Safety Director, HPC Site Construction Director and Pre-
Operations Director are shown below:
2.5.3 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.
2.5.4 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.
2.5.5 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.
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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):
2.6.1 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.
2.6.2 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-2009. 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.
101. 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.
102. The Chairman of the NSC also has direct access to the MD on safety and
environmental issues.
103. 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;
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• 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.
104. The terms of reference and membership of the NSC are in Ref 16.
2.6.3 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.
106. 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.
2.6.4 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.
108. 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;
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• 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.
2.6.5 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.
110. The Investment Committee has responsibilities in relation to capital spend on
procurement contracts, asset investments (or divestments) and business change
projects.
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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 203 458.
112. 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.
113. NNB GenCo intends to design, construct, commission, operate and decommission two
UK EPR reactors on the HPC site.
114. 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.
115. 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.
116. 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.
117. 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.
118. The leases will give NNB GenCo exclusive possession and therefore the right to control
access to the site.
119. 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.
120. NNB GenCo will have overall control of activities at the site throughout the construction
period (and beyond) supported by the AE.
121. 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.
122. 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.
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3.2 Basic EPR Description

123. The HPC Site will have two UK EPR’s.
124. 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.
125. 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.
126. 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.
127. 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.
128. 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;
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• 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.
129. An illustration of the completed HPC site is shown in Figure 3.
130. 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

3.3.1 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.
132. NNB GenCo will be submitting a FDP for HPC to the DECC for approval pursuant to
Section 45 of the Energy Act 2008.
133. 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.
134. 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.
135. 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.
136. An approved FDP will be in place prior to commencement of the construction phase.
3.3.2 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.
3.3.3 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.
139. 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.
140. 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
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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.
141. 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.
142. 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.
143. 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.
3.3.4 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.
145. 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).
146. 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.
147. 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 2009.
148. 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 2011.
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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.
150. NNB GenCo will not proceed beyond preliminary works on the HPC site without receipt
of the DCO.
3.3.5 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 2010. Some permits will be relatively limited in scope and will only affect
activities undertaken in the construction phase.
152. 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.
153. 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.
154. 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.
155. 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.
156. 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
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activities including consultation on the draft permit and their decision document. Their
approach is tailored to specific local circumstances.
157. 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.
159. 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 safety-
related 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.
160. 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
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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.
161. 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.
3.4.1 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.
163. The NNB GenCo process for defining, managing and releasing these hold points is
described in Ref 17, including the management of ONR & EA permissions.
164. 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.
165. It should be noted that the Hold Point List will develop and change as the project
progresses.
166. 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
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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.
167. 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.
169. 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.
170. 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.
171. 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.
172. 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.
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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.
174. 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.
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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.
176. 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.
177. 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: 2007.
178. The management system manual applies to all phases of the project life cycle and for
the entire duration of activities.
179. 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.
180. The full management system is presented in the Management System Manual [Ref
18], a summary is presented herein relevant to the MP.
181. 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.
183. 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.
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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:
4.3.1 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.
187. 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.
4.3.2 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.
189. 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.
4.3.3 Assurance
190. Process Group Objective: To provide confidence that technical, health & safety, quality,
nuclear, environmental and security requirements are complied with.
191. Process Group Description & Scope: To perform business, technical and regulatory
assurance activities and to address non-conformances.
192. 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;
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• 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.
4.3.4 Continuous Improvement

193. Process Group Objective: To provide a Continual Performance Improvement framework
that enables the organisation to learn and improve.
194. 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.
• 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:-
4.4.1 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.
198. 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.
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• Manage Documents Originated by NNB GenCo;

• Manage Documents Received by NNB GenCo;
• Review Documents, Records & Physical Samples;
• Store Physical Samples; and
• Dispose of Records.
4.4.2 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.
201. 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.
• 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.
4.4.3 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.
204. 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.
• 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;
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• Develop Training;
• Implement Training; and
• Evaluate Training;
4.4.4 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.
207. Process Group Description & Scope: To manage external communication.
4.4.5 Finance
208. Process Group Objective: To provide financial accounting services and manage the
interface with EDF Energy Shared Service teams.
209. Process Group Description & Scope: To provide financial accounting support, to
manage the payroll and to prepare periodic reporting to EDF Energy.
4.4.6 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.
211. Process Group Description & Scope: The planning, acquisition, implementation,
monitoring, evaluation, delivery and support of the IS services used to manage NNB
GenCo information.
4.4.7 Properties and Facilities

212. Process Group Objective: To provide property and facilities services that satisfy both
internal and external (regulatory) stakeholders.
213. Process Group Description & Scope: The provision of property and facilities
management services at designated NNB GenCo sites.
4.4.8 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.
215. 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.
• 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;
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• 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:
4.5.1 Project Management

218. Process Group Objective: To manage the UK EPR Programme through the pre-
construction, construction, non-active commissioning, radioactive commissioning,
operation and de-commissioning phases, within the constraints of Safety, time, cost and
quality requirements.
219. Process Group Description & Scope: To plan, organise, secure and manage the
resources required to successfully complete the UK EPR Programme.
4.5.2 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.
221. 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.
• 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;
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• 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.
4.5.3 Procure
223. 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.
224. Process Group Description & Scope: To manage all the activities in support of the
procurement of goods and services for the construction of nuclear plants.
• 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.
4.5.4 Manufacture
226. Process Group Objective: To supply components and equipment in accordance with
specified requirements.
227. Process Group Description & Scope: to provide assurance of the correct application of
contractual arrangements and the conformity of components and equipment with
specified requirements.
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.
4.5.5 Construct
230. Process Group Description & Scope: To manage the construction programme and
discharge the responsibilities of the ‘Intelligent Customer’ in relation to the AE.
• 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;
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• 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 non-
conformances, capture the “as built” design and to approve handover from the
contractor;
• Manage Construction Change;
• Handover to Commissioning; and
• Dismantle Temporary Structures.
4.5.6 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.
233. 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.
• 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.
4.5.7 Operate
235. Process Group Objective: To ensure the safe, reliable and efficient running of the
station.
236. 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.
4.5.8 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.
238. 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.
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• 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.
4.5.9 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.
241. 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.
• Manage Pre-Application Activity;
• Prepare Application;
• Obtain Consents, Permits & Licences; and
• Change Consents, Permits & Licences.
Page 46 of 58
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.
244. 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.
245. 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.
246. Like the MP, the NB will be updated at appropriate intervals to take account of changes
to the organisation.
247. The NB also identifies vulnerabilities and the associated mitigation.
248. 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
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.
251. 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.
252. The arrangements once implemented will consider the cumulative effect of changes on
the organisation and identify any mitigation necessary.
253. 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.
255. 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.
256. 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.
257. 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.
258. 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.
259. 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.
260. 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
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.
262. 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.
263. 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.
264. Organisational Learning in NNB GenCo covers safety, environment, health and security.
265. NNB GenCo will identify, communicate and where appropriate, make recommendations
and implement them to ensure lessons are learnt.
266. 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.
268. 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.
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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.
271. 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.
272. 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
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.
274. 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.
275. 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.
276. 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.
277. The FWP also describes when the procedures, arrangements and organisation will be
reviewed or changed going forward up to operation.
Page 51 of 58
7 CONCLUSION
278. The Management Prospectus (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 Management Prospectus –
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.
279. 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
APPENDIX A FIGURES
Figure 1: Corporate Structure, ownership and HPC land leases to NNB GenCo
Page 53 of 58
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
Figure 4: NNB GenCo Board
Figure 5: NNB GenCo Executive Team
Page 55 of 58
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
Figure 8: NNB GenCo Process Groups
Page 57 of 58
APPENDIX B NNB GENCO – HEALTH, SAFETY,

ENVIRONMENT AND QUALITY POLICY
Page 58 of 58

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NNB GENERATION COMPANY LTD

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MANAGING DIRECTOR’S STATEMENT

3 THE UK EPR FOR HINKLEY POINT C................................................................................29

3.3.3 Generic Design Assessment ........................................................................................ 31

6 FORWARD WORK PLAN.................................................................................................... 51

APPENDIX A FIGURES .......................................................................................................... 53

APPENDIX B NNB GENCO – HEALTH, SAFETY, ENVIRONMENT AND QUALITY

• Recruitment of staff commensurate with the Resourcing Strategy [Ref 12]

1.1 References and Definitions

1 NNB GenCo Nuclear Baseline v2 EDRMS NNB-HRE-ASS-000001

HSE – NSD Safety Assessment Principles for HSE Website http://www.hse.gov.uk/nu

Function and content of a safety management HSE Website http://www.hse.gov.uk/foi

HSE Website http://www.hse.gov.uk/nu

HSE Website http://www.hse.gov.uk/foi

Licensee design authority capability HSE Website http://www.hse.gov.uk/foi

HSE Website http://www.hse.gov.uk/foi

Licensee use of contractors and intelligent HSE Website

13 NNB GenCo Company Manual EDRMS NNB-OSL-MAN-000002

Application for a Nuclear Site Licence for Hinkley EDRMS

15 Internal Challenge and Oversight Strategy EDRMS NNB-OSL-STR-000007

Terms of reference and membership of the NNB EDRMS

NNB GenCo Company Procedure – Define, EDRMS

Ref Title Location Document No.

18 NNB GenCo Management System Manual EDRMS NNB-OSL-MAN-000004

Forward Work Plan for Hinkley Point C Nuclear EDRMS

Term / Abbreviation Definition

Term / Abbreviation Definition

2.1 The Company

2.1.2 NNB GenCo Vision and Values

2.1.3 Organisation of NNB GenCo

2.2 The Role of the Architect Engineer and Responsible

2.2.1 Architect Engineer

2.2.2 Responsible Designer

2.3 The NNB GenCo Board

2.3.2 Governance, Risk Management and Internal Control

2.3.3 Safety Governance

• Informing the NNB Holding Company Technical Committee on all relevant

2.4 Membership of the Board

2.4.1 Managing Director

2.4.2 Project Director HPC

• Management of all on and off site construction and commissioning from

2.4.3 Client Construction Director

2.4.4 EPR Architect Director

2.4.5 Planning and External Affairs Director

2.4.6 Finance Director

2.4.7 Human Resources Director

2.4.8 Non Executive Directors

2.4.9 Company Secretary

2.5 NNB GenCo Executive

2.5.2 Membership of the Executive

2.5.3 Safety Director

2.5.4 HPC Site Construction Director

2.5.5 Pre-Operations Director

2.6.1 Safety, Health and Environment Committee

2.6.2 Nuclear Safety Committee

• Such arrangements or documents required by the NSL Conditions as the ONR

2.6.3 Construction Committee

2.6.4 Operational Control Committee

• Reviewing allocation of resources and operating expenditure within NNB

2.6.5 The Investment Committee

3 THE UK EPR FOR HINKLEY POINT C

3.1 The Hinkley Point C Site