Nnb Generation Company (Szc) Ltd

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NNB GENERATION COMPANY (SZC) LTD

COMPANY DOCUMENT

APPLICATION FOR NUCLEAR SITE LICENCE- SIZEWELL C

HEAD DOCUMENT

© 2020 Published in the United Kingdom by NNB Generation Company (SZC) 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 GenCo, 90 Whitfield Street, London W1T 4EZ. The electronic copy is the current issue and printing renders this document uncontrolled.)

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1 INTRODUCTION ...... 5

2 APPROACH TO THE DEVELOPMENT OF THE APPLICATION ...... 5

3 REFERENCES AND DEFINITIONS ...... 6

4 THE APPLICATION FOR NUCLEAR SITE LICENCE ...... 9 4.1 NSL for Sizewell C ...... 9 4.2 The NSL Application Dossier ...... 9 4.3 Third Party Nuclear Liability Insurance ...... 10 4.4 Description of the Activities to be Licensed ...... 10

5 DESCRIPTION OF THE APPLICANT ...... 11 5.1 Description of NNB GenCo (SZC) and its Shareholders ...... 11 5.2 Arrangements for the Design and Construction of SZC ...... 11

6 PROPOSED LOCATION AND NNB GENCO (SZC)’S CONTROL OF THE SZC SITE ...... 12 6.1 Location of Proposed SZC Site ...... 12 6.2 NNB GenCo (SZC)’s Control of the SZC Site ...... 13

7 THE NUCLEAR SITE LICENCE DOSSIER ...... 13 7.1 Company Manual ...... 13 7.2 Nuclear Baseline ...... 14 7.3 Management System Manual ...... 14 7.4 SZC Pre-Construction Safety Report ...... 15 7.5 Licence Condition Compliance Matrix ...... 16 7.6 Forward Work Plan ...... 16 7.7 The Nuclear Safety Committee ...... 16 7.8 SZC NSL Site Plan and Arrangements for Leasing ...... 17

8 NUCLEAR RELATED PERMITS, AUTHORISATIONS AND PLANS REQUIRED BY OTHER AUTHORITIES ...... 17 8.1 Generic Design Assessment ...... 17 8.2 The Justification Decision...... 17 8.3 Government Siting Policy ...... 18

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8.4 Development Consent Order ...... 18 8.5 Environment Agency Permits and Authorisations ...... 18 8.6 Article 37 of the Euratom Treaty on Radioactive Waste Disposal ...... 19 8.7 Department for Transport Dangerous Goods Division ...... 19 8.8 Article 41 of the Euratom Treaty on Nuclear Activities ...... 20 8.9 Funded Decommissioning Programme and Decommissioning Strategy ...... 20 8.10 Security Plan...... 21 8.11 Safeguards...... 22 8.12 Emergency Plan ...... 22

APPENDIX A CORRELATION OF THE NSL APPLICATION DOSSIER WITH ONR GUIDANCE ...... 23

APPENDIX B CORPORATE STRUCTURE OF NNB GENCO (SZC) ...... 25

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1 INTRODUCTION

NNB Generation Company (SZC) Ltd (NNB GenCo (SZC)) was incorporated on 28th October 2014 as a private limited company, company number 092842825. NNB GenCo (SZC) registered office is at 90, Whitfield Street, London W1T 4EZ. NNB GenCo (SZC) is applying to Her Majesty’s Chief Inspector of Nuclear Installations for a Nuclear Site Licence (NSL) to install and operate a nuclear installation at its site at Sizewell C (SZC). It is the intention of NNB GenCo (SZC) to construct two EPR units at SZC, units SZC1 and SZC2.

This Head Document provides an overview of the Application and summarises the contents of the Application Dossier. The Head Document also summarises the current position on nuclear related permits and authorisations required by other authorities together with nuclear related plans and programmes. 2 APPROACH TO THE DEVELOPMENT OF THE APPLICATION

NNB GenCo (SZC) has utilised Office for Nuclear Regulation (ONR) guidance in developing this Application. In particular, the Application is structured to address ONR guidance set forth in “The Processing of Licence Applications for New Nuclear Sites” [Ref. 1], and The Licensing of Nuclear Installations [Ref. 2]. These documents identify supporting evidence that should be provided as part of an application. Appendix A provides a route map that identifies the section of the Application that provides information addressing the topics specified in the ONR’s guidance documents.

NNB GenCo (SZC)’s approach to the SZC project and developing this Application is to utilise best practices and to take advantage of the guidance prepared by the ONR and international organisations including the International Atomic Energy Agency (IAEA), the World Association of Nuclear Operators (WANO) and the Institute of Nuclear Power Operators (INPO) in developing the organisation of NNB GenCo (SZC) and its policies and standards. As discussed below, NNB GenCo (SZC) is also taking advantage of the best practices of its parents and affiliates, and the current project at Hinkley Point C (HPC), and intends to replicate wherever possible the design and technology of HPC to be used in SZC.

NNB GenCo (SZC)’s overarching approach has been to develop management and operational arrangements that are fit for purpose and has included these arrangements in a Compliance Matrix for the current and future phases of the project to assure compliance with all 36 standard licence conditions. The Compliance Matrix is discussed later this document and is set out in the NSL Application Dossier.

NNB GenCo (SZC) will produce, implement, and test appropriate arrangements for each phase of the SZC project through shadow working. This phased approach will allow sufficient time for NNB GenCo (SZC) to identify lessons learned and make improvements, and for the Office for Nuclear Regulation (ONR)

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inspection of the arrangements to assure effective implementation. NNB GenCo (SZC) has established a Forward Work Plan (FWP) to set out, produce, implement, and test arrangements for those phases in advance of them being required. The FWP is discussed in Section 7.6 of this document and is set out in the NSL Application Dossier.

NNB GenCo (SZC)’s organisation and arrangements will evolve over time as the phases of the project change. These phases are not necessarily distinct and may overlap. In addition, construction of the two EPR units at SZC will be staggered, such that Unit SZC1 is expected to become operational while Unit SZC2 is still undergoing construction and commissioning.

Each of these phases of the SZC project will necessitate changes to the organisation as well as to controls and programmes. Furthermore, even within a phase, the organisation and programmes may need to change depending upon the activities being conducted and to reflect lessons learned. NNB GenCo (SZC) fully appreciates that phases of the SZC project will overlap, and therefore there will be times when NNB GenCo (SZC) will be required to have established and be simultaneously implementing organisational and programmatic controls for more than one phase.

Since NNB GenCo (SZC) was established, the Company has developed its organisational structure and will continue to develop as a prospective nuclear licensee. During this time, NNB GenCo (SZC) has been supported by its parent Electricité de France SA (EDF SA) and its UK affiliates. EDF SA is the world’s largest operator of nuclear power plants and has in-depth experience of all the phases of nuclear power plant projects, from pre-construction through to operation and decommissioning. EDF SA has made arrangements for NNB GenCo (SZC) to have access to EDF SA’s resources, knowledge, experience and expertise, and that of EDF UK particularly that of NNB Generation Company (HPC) Limited (NNB GenCo (HPC)), which is developing HPC; however, as the intelligent customer (IC) and operator of SZC, NNB GenCo (SZC) has established and will continue to develop its organisation and procedures, in line with the development of the SZC project.

Separately from this Application, NNB GenCo (SZC) is also applying to other regulatory bodies for various permits related to the construction and operation of SZC, including authorisation from the Environment Agency (EA) to dispose of radioactive waste from SZC. 3 REFERENCES AND DEFINITIONS

Ref Title Location Document Number/ Revision 1 The Processing of Licence Applications for New Nuclear ONR Website http://www.onr.org.uk/operational/ Sites. NS-PER-IN-003, Revision 4 assessment/ns-per-in-003.pdf 2 Licensing Nuclear Installations. 5th edition: Sept 2019. ONR Website http://www.onr.org.uk/licensing- nuclear-installations.pdf 3 GDA Approval EPR70475N 13/12/2012 ONR Website http://www.onr.org.uk/new- reactors/reports/step-four/closeout/epr70475n.pdf

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4 Nuclear Site Licence Conditions. February 2017 ONR Website http://www.onr.org.uk/documents/li cence-condition-handbook.pdf 5 NNB GenCo (SZC) Company Manual EDRMS 100200192 6 NNB GenCo (SZC0 Nuclear Baseline EDRMS 100200200 7 NNB GenCo (SZC) Management System Manual EDRMS 100200202 8 Justification of Practices Involving Ionising Radiation. BEIS Website https://assets.publishing.service.gov. Oct 2010 uk/government/uploads/system/upl oads/attachment_data/file/47936/6 66-decision-EPR-nuclear-reactor.pdf 9 National Policy Statement for Nuclear Power BEIS website https://assets.publishing.service.gov. Generation. Nov 2009 uk/government/uploads/system/upl oads/attachment_data/file/228630/ 9780108508332.pdf 10 Security Assessment Principles for the Civil Nuclear ONR Website http://www.onr.org.uk/syaps/securit Industry. 2017 y-assessment-principles-2017.pdf 11 The Radiation (Emergency Preparedness and Public Government http://www.legislation.gov.uk/uksi/2 Information) Regulations, 2019 Website 019/703/contents/made

Term / Definition Abbreviation BAT Best Available Technique BEIS Government Department of Business Enterprise and Industrial Strategy BS British Standard CAP Corrective Action Plan CNSS Civil Nuclear Security and Safeguards DA Design Authority DAC Design Acceptance Confirmation DCO Development Consent Order DIPNN Division Ingénierie Projet Nouveau Nucléaire, The engineering division of EDF SA EA Environment Agency EDF SA Electricité de France Société Anonyme EDF UK EDF Energy (UK) Limited and its subsidiaries 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 HPC Hinkley Point ‘C’ HR Human Resource HSE Health and Safety Executive IACO Independent Assessment, Challenge and Oversight

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IAEA International Atomic Energy Agency IC Intelligent Customer IEC International Electro-Technical Commission IMS Integrated Management System INPO Institute of Nuclear Power Operators IS Information System ISO International Standards Organisation ITA Independent Technical Assessment JSSR Justification of Site Suitability Report KM Knowledge Management KPI Key Performance 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 (SZC) Ltd (SZC) NNB GenCo NNB Generation Company (HPC) Limited (HPC) 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 Health and Safety Management System ONR Office for Nuclear Regulation ONR CNSS Office for Nuclear Regulation, Civil Nuclear Security and Safeguards. OPEX Operating Experience PCER Pre-construction Environmental Report PCSR Pre-Construction Safety Report PINS Planning Inspectorate PWR Pressurised Water Reactor QA Quality Assurance RD Responsible Designer RSR Radioactive Substances Regulation SDSR Site Data Summary Report 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

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SZA Sizewell A SZB Sizewell B SZC Sizewell C UK United Kingdom WANO World Association of Nuclear Operators WENRA Western European Nuclear Regulators Association

4 THE APPLICATION FOR NUCLEAR SITE LICENCE

4.1 NSL for Sizewell C

NNB GenCo (SZC) is applying to the ONR for a NSL to install and operate two EPR reactors at SZC. The EPR design has been subject to a Generic Design Assessment (GDA) which was approved on 13th December 2012, ONR reference EPR70475N, [Ref 3], and it is intended to replicate the design under construction as part of the HPC project, incorporating UK learning.

As described further in this Application, NNB GenCo has established itself as a corporate body and has established a suitable management organisation to be a competent Licensee and operator of a nuclear site and an Intelligent Customer. NNB GenCo (SZC)’s management and organisation will continue to evolve to support project needs.

This Application provides information that demonstrates that NNB GenCo (SZC) should be granted a NSL for SZC, including sufficient information to demonstrate that NNB GenCo (SZC) has a suitable management organisation to oversee further development of the design and commencement of safety related construction. Additionally, this Application shows that NNB GenCo (SZC) will have sufficient arrangements at the time of granting of the NSL to conduct design, procurement, and initial construction activities. Thereafter, development and improvement of management arrangements will be a continuous process.

It is the intention of NNB GenCo (SZC) to seek renewal of the EPR Design Acceptance Certificate, originally issued 13th December 2012 at the end of its ten-year period of validity, based upon the justification being prepared for replication of design.

4.2 The NSL Application Dossier

This Application is organised into six parts as described below,

 Part 1 consists of this Head Document which provides introductory material and a summary of the Application including the status of other nuclear-related permits and authorisations. Part 1 also includes the list of acronyms and glossary of terms used throughout the application.

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 Part 2 provides the Company Manual which describes the organisation of the Board and the Directors of NNB GenCo (SZC) (and incorporates the management safety prospectus) and the Nuclear Baseline (NB) for the NNB GenCo (SZC) organisation.

 Part 3 includes corporate governance documents such as the Articles of Association; NNB GenCo (SZC) Policy Statements as they relate to this Application; the Terms of Reference for the Nuclear Safety Committee (NSC); and NNB GenCo (SZC)’s Management System Manual that encompasses arrangements for compliance with licence conditions, environmental regulations, safety regulations, and normal business processes.

 Part 4 provides the Nuclear Site Licence Compliance Matrix. NNB GenCo (SZC) will have in place proportionate arrangements consistent with each phase of the Project to comply with each Licence Condition (LC), including a shadow working period to review the arrangements and implement improvements to address lessons learned.

 Part 5 sets out NNB GenCo (SZC)’s FWP for the continued development of the organisation and the Pre-Construction Safety Report (PCSR) and arrangements for later phases of the project, such as commissioning and operation.

 Part 6 contains a proposed SZC Nuclear Site Licence Area for SZC, and a preliminary plot plan and list of buildings, and the Site Data Summary Report (SDSR) and Justification of Site Suitability Report (JSSR).

4.3 Third Party Nuclear Liability Insurance

NNB GenCo (SZC) will be seeking approval from BEIS that the cover period under section 19 (1) of the Nuclear Installations Act 1965 (as amended) shall be effective from the date of initial receipt of fuel at SZC. NNB GenCo (SZC) has not, as yet, received such approval but will either have such approval in place at the time of granting of the NSL or shall make such provision (either by insurance or by some other means) for sufficient funds to be available at all times to ensure that any claims which have been or may be duly established against NNB GenCo (SZC) as licensee of SZC under the provisions of section 7 of the NIA can be settled.

4.4 Description of the Activities to be Licensed

In compliance with section 1 of the Nuclear Installations Act 1965 (as amended) and with section 3(6) of the Nuclear Installations Regulation 1971 (SI 1971/381), and in accordance with “The Processing of Licence Applications for New Nuclear Sites” [Ref 1], and “Licencing Nuclear Installations” [Ref 2], NNB GenCo (SZC) is applying for a nuclear site licence for the purpose of installing and operating a nuclear reactor and for storage of irradiated nuclear fuel and other radioactive matter.

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Specifically, NNB GenCo (SZC) is applying to the ONR for a NSL for SZC to perform the following activities:  Install two EPRs, with associated site-specific structures and systems, to be designated as Sizewell C, Units C1 and C2. NNB GenCo (SZC) is planning to stagger construction of the units,  Operate the Units; and Store irradiated nuclear fuel or bulk quantities of any other radioactive matter which has been produced or irradiated during the use of nuclear fuel.

5 DESCRIPTION OF THE APPLICANT

5.1 Description of NNB GenCo (SZC) and its Shareholders NNB GenCo (SZC) is a private limited company (Registered in England and Wales with Company Number 09284825. It is a wholly owned subsidiary of NNB Holding Company (SZC) Ltd, which in turn is owned by EDF Energy Holdings Limited (80% owner) and General Nuclear International (20% owner). EDF Energy Holdings Limited is a wholly owned subsidiary of EDF Energy (UK) Limited, which is a wholly owned subsidiary of EDF International SAS, which is a wholly owned subsidiary of EDF SA. General Nuclear International is a wholly owned subsidiary of China General Nuclear Power Corporation. This corporate structure is depicted in Appendix B. Although NNB GenCo (SZC) is a subsidiary of an experienced constructor and operator of nuclear power plants, NNB GenCo (SZC) will be structured to have sole responsibility for licensed activities related to the control, design, construction, commissioning, operation, maintenance and eventual decommissioning of SZC. NNB GenCo (SZC) will have control of all licensed activities per the NSL (Ref 4) required to be conducted under the SZC NSL and control of all activities required under the terms and conditions of other permits and authorisations.

5.2 Arrangements for the Design and Construction of SZC The plant at Sizewell C will be, wherever possible, an replica of the power plant being constructed by NNB GenCo (HPC) at Hinkley Point C, with the only changes being related to geology, geographical position, and the marine environment. It is the intention to demonstrate to the ONR that this is acceptable and will be the justification of the extension to the validity of the DAC. The RD, EDF SA, NNB GenCo (HPC), EDF UK or any other engineering, technical or support organisation will have clear reporting obligations to NNB GenCo (SZC) which are to be set out in an agreement between the parties, which will be completed prior to granting of the NSL. The governance arrangements between NNB GenCo (SZC) and EDF SA / NNB GenCo (HPC) include the requirement for NNB GenCo (SZC) approval of EDF SA proposals for all matters with a potential to affect safety, including nuclear safety and requires NNB GenCo (SZC) to review and formally accept all significant design changes, documentation and project works. This arrangement provides NNB GenCo (SZC) with the

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benefit of the considerable engineering and construction experience of the EDF SA and NNB GenCo (HPC) organisation, while retaining ultimate responsibility as the Licensee. NNB GenCo (SZC) will take advantage of the knowledge and experience of its contractors and vendors. However, NNB GenCo (SZC) will be an IC and is developing the capability within its own organisation, in terms of staffing and expertise, to understand, own and control the safety case for the SZC EPR, the site- specific structures and systems for SZC and the limits and conditions under which they will be operated. NNB GenCo (SZC) will also maintain oversight of and retain responsibility for the work and activities of its contractors and vendors in accordance with its procedures. NNB GenCo (SZC) will ensure through selection, recruitment, and training that its staff have sufficient breadth, depth, and competence to carry out its nuclear safety duties. NNB GenCo (SZC)’s actions to accomplish these objectives and be an IC are discussed in more detail in the Company Manual, the NB and FWP and will assure compliance with the standard licence conditions, as described in Parts 2 and 5 of the Application. NNB GenCo (SZC) will have in place an agreement with EDF SA, prior to granting of the NSL, to serve as the Responsible Designer for SZC. The principal engineering role is being performed by the Division Ingénierie Projet Nouveau Nucléaire (DIPNN) of EDF SA, under the overall control of NNB GenCo (SZC). This role includes the production of documentation required to design, construct, commission and operate the plant. NNB GenCo (SZC) will remain responsible for the design (principally through its Design Authority (DA) organisation). This will require that NNB GenCo (SZC) act as an IC, able to specify requirements and determine that the outputs meet these requirements, as well as to place constraints on the organisations performing the detailed design work consistent with maintaining overall control.

6 PROPOSED LOCATION AND NNB GENCO (SZC)’S CONTROL OF THE SZC SITE

6.1 Location of Proposed SZC Site SZC will be located at Sizewell, on the coast of the County of Suffolk. It will be within the civil parish of Leiston-cum-Sizewell in the District of East Suffolk. The proposed site for SZC is located to the north of two existing nuclear installations, Sizewell A (SZA) and Sizewell B (SZB). Part of the SZC Site will be located within the current SZB licensed site which will be re-licensed. The grid reference of the approximate centre of the SZC site is at Lat.- 52.213200 Long.- 1.6162560. SZA is a two-unit Magnox nuclear power plant now de-fuelled and under decommissioning by Magnox Limited under contract with the Nuclear Decommissioning Authority (NDA). SZB is an operating single unit Pressurised Water Reactor (PWR) nuclear power plant operated by EDF Energy Nuclear Generation Limited.

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Further information relative to the site appears in Part 6 of the Application, which identifies the proposed licensed site.

6.2 NNB GenCo (SZC)’s Control of the SZC Site NNB GenCo (SZC) will be the sole user of the proposed SZC site and will obtain the permission of the ONR under Nuclear Site Licence Condition 3 for any shared use of the site in the future as appropriate.

7 THE NUCLEAR SITE LICENCE DOSSIER

7.1 Company Manual The Company Manual for NNB GenCo (SZC) [Ref 5] provides an overview of NNB GenCo (SZC) and describes its Vision and Values and acts as the “Management Prospectus” for the company. It describes the organisational structure of NNB GenCo (SZC) and its governance arrangements, including its Board and Committee structure. It summarises the principal governance framework approved by the NNB GenCo (SZC) Board of Directors and its policies. The Company Manual provides an overarching demonstration of how nuclear safety, environmental protection, quality, and security are managed within the organisation and shows how the assurance arrangements are robust now and how they will develop in the future as the project progresses. It will be maintained to reflect changes to the organisational structure and governance arrangements of NNB GenCo (SZC). The Company Manual provides a clear description of the type of activities to be carried out on the SZC licensed site. It describes how the organisational structure of NNB GenCo (SZC) meets the nuclear safety management needs of the business and sets out NNB GenCo’s approach to the governance of nuclear safety. It provides the strategy for developing and maintaining a licensable organisation, with suitable resources and competences to deliver nuclear safety. It outlines how NNB GenCo (SZC) considers and responds to lessons, both from within and outside the organisation, setting out clearly NNB GenCo’s approach to managing change. The Company Manual demonstrates how NNB GenCo (SZC) is the ‘controlling mind’ and will have oversight of activities that may have an impact on nuclear safety and environmental protection. NNB GenCo (SZC) has sufficient, competent resources to act as an IC at this phase of the project. NNB GenCo (SZC) has identified nuclear safety related roles and posts for the baseline organisation. Sufficient, competent resources will be made available at the right time to fulfil those roles as the organisation develops, noting that the first nuclear safety related concrete will be approximately 4 years post issue of the NSL and the Financial Investment Decision, due to the extent of early preparatory works on the SZC site. The Company Manual demonstrates that NNB GenCo (SZC) will have appropriate oversight of the design and construction activities now and in the future and that there is a suitable management system to enable NNB GenCo (SZC) to operate and demonstrate nuclear safety at this time.

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Company Document NOT PROTECTIVELY MARKED 7.2 Nuclear Baseline The Nuclear Baseline (NB) [Ref 6] describes the organisational design, structure, roles, and numbers of personnel required to deliver and maintain nuclear safety in all its forms, including environmental protection and security compliance. The NB is an integral part of the arrangements that demonstrate that NNB GenCo (SZC) is a capable licensee and holder of environmental permits and consents. NNB GenCo (SZC) recognises the importance of the NB throughout the lifecycle of the project and has developed an approach that draws on best practices from the Nuclear Industry Code of Practice, the IAEA, WANO, ONR and EA guidance. The NB demonstrates NNB GenCo (SZC) has the organisation, resources and competences needed for the current phase of the project and how it is preparing for the future phases. The NB has several purposes:  To demonstrate, and provide assurance, that NNB GenCo (SZC) has suitable and sufficient organisational structures, resources and competence to be able to carry out, safely and effectively, all activities that may impact on nuclear safety;  To provide a baseline against which changes to the organisational design, structure and resources can be assessed and managed;  To demonstrate that NNB GenCo (SZC) is in control of activities through the right allocation of responsibilities for all work that has the potential to impact on nuclear safety;  To demonstrate how responsibilities for nuclear safety, environmental protection and security are allocated across the organisation to achieve legal compliance; and  To provide an overview of the staffing levels for the existing phase and a look ahead to the future. The NB that accompanies the Application, identifies posts and roles for the Pre-Licencing phase, with a look ahead to the next phase as appropriate. This NB will build on previous versions. There will be some further refinements to the structure as it is implemented ahead of the Construction phase. This NB should be read as an interim position, which will be updated prior to granting of the NSL. It should also be noted that as SZC is intended to be a replica plant, the staff numbers within NNB GenCo (SZC) will be less than those within the HPC organisation at this stage, the engineering design works, works associated with project management and the Design Authority numbers are significantly less than that of a first of a kind project such as HPC.

7.3 Management System Manual The Management System Manual, [Ref 7] submitted in Part 3 of the Application, is part of the IMS and describes the over-arching and integrated business process framework for NNB GenCo (SZC). This establishes the structure in which the underlying processes and procedures will be developed, in conjunction with its sister project at HPC to maximise the benefits of organisational learning and in line with intelligent replication.

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The IMS, described in the Management System Manual, consists of various components. At the highest level, the Company’s vision and values guide NNB GenCo (SZC)’s actions. NNB GenCo (SZC) also has strategic objectives that factor into its processes, which include management processes, core processes, and support processes. NNB GenCo (SZC) further utilises performance measures that help NNB GenCo (SZC) to review, learn, and improve.

7.4 SZC Pre-Construction Safety Report The baseline for the SZC PCSR is that developed by NNB GenCo (HPC) at the Reference Configuration 2 (RC-2) stage which is the detail design developed from the approved GDA. There are several site-specific analyses to complete the justification. These are ongoing and will result in a series of technical documents being prepared. The PCSR forward plan will ensure these submissions and assessments are complete ahead of the related construction commencing. The SZC PCSR will develop analyses and will interact with the ONR on a range of technical topics continues, including:  analysis to confirm that the GDA and HPC bounding analysis encompasses the SZC site characteristics.  Design, performance, and justification of the site-specific heat sink; and  Analysis of any site-specific hazards. The SZC PCSR will:  Justify that the plant design is adequately safe to progress into the construction phase, including a safety justification of a twin reactor site, the disposal routes for waste and fuel,  Provide the basis to seek consent to construct once the development of the design is sufficiently detailed to support this,  Define the SZC Reference Design,  Illustrate the safety case production, review, and acceptance processes; and  Demonstrate the suitability of the site including validation of the bounding characteristics of the GDA site envelope for SZC and provide confidence that any parameters that are not bounded (or deviate from the GDA) can be suitably justified. NNB GenCo (SZC) will prepare and submit a schedule of safety submissions which will address the bounding character of the GDA, justification of the twin reactor site, further site-specific design information, further SZC site data and external hazard analysis. These submissions are an integral part of the PCSR being prepared to support and justify construction. Areas of organisational capability with respect to production, review ownership and IC processes will be explained and established in LC compliance arrangements and company manual. It is NNB GenCo’s intent to apply these arrangements to the SZC PCSR.

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PCSR is the first step on the safety case production and will be followed later in the development of the SZC project by the Pre-Operational Safety Report (POSR) and Station Safety Report (SSR) for operation. The SZC safety case will consider the impact of adjacent facilities. NNB GenCo (SZC) will liaise with SZA and SZB, to identify and help assess the impact of any potential hazards associated with the construction and operation of SZC on the SZA and SZB safety cases.

7.5 Licence Condition Compliance Matrix NNB GenCo (SZC) has developed appropriate and proportional arrangements for achieving compliance with the ONR’s 36 standard nuclear site licence conditions [Ref. 4]. In developing these arrangements and plans, NNB GenCo (SZC) considered applicable legislation, ONR guidance, EDF processes, international standards and learning from HPC. The Application builds on NNB GenCo (SZC)’s Strategies and Compliance Statements to ensure that appropriate arrangements will be fully developed for all Licence Conditions by the appropriate phase in the project lifecycle. Part 4 of the Application provides a consolidated Compliance Matrix. The Compliance Matrix outlines the approach that will be taken by NNB GenCo (SZC) to ensure the project complies with each of the 36 LCs.

7.6 Forward Work Plan NNB GenCo (SZC) has an organisation and arrangements in place that are fit for purpose for the current phase of the project and the FWP describes future developments to ensure NNB GenCo (SZC) continues to be an IC and Licensee. The FWP is an integral part of the Application and provides a description of the plans and activities being carried out by NNB GenCo (SZC), in order to achieve readiness for granting of the NSL and to put in place appropriate and proportionate arrangements to support the SZC project lifecycle phases. This includes plans for developing the organisation, associated management arrangements and safety cases for the later phases.

7.7 The Nuclear Safety Committee LC 13 provides that the licensee shall establish a nuclear safety committee or committees to which it shall refer for consideration and advice regarding the following:  matters required by or under these conditions to be referred to a nuclear safety committee,  Such arrangements or documents required by the ONR 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

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 Any other matter which the licensee considers should be referred to a nuclear safety committee. In compliance with LC 13, NNB GenCo (SZC) is submitting to the ONR for approval the terms of reference of the NNB GenCo (SZC) Nuclear Safety Committee. These are included in Part 3 of the Application Dossier.

7.8 SZC NSL Site Plan and Arrangements for Leasing A plan of the proposed SZC Licenced Site boundary is marked by a red line and provided in Part 6 of the Application. The SZC Licensed Site comprises of land already owned by EDF Energy Nuclear Generation Limited, this will transfer as freehold to NNB GenCo (SZC) at or around FID and land within this area that is currently licenced under the SZB nuclear site licence will be re-licenced to SZC as part of the licencing arrangements.

8 NUCLEAR RELATED PERMITS, AUTHORISATIONS AND PLANS REQUIRED BY OTHER AUTHORITIES

8.1 Generic Design Assessment The Generic Design Assessment (GDA) is the process by which the nuclear regulators, the ONR and the Environment Agency (EA), assess the suitability of new nuclear reactor designs for construction in the UK. This process allows the regulators to assess the safety, security, and environmental implications of the design, enabling the identification of any potential issues so that they can be addressed by the requesting parties (the companies who have submitted a design for assessment) before commitments are made to construct the reactors. The EPR design has been subject to a Generic Design Assessment (GDA) which was issued a Design Acceptance Confirmation by the ONR and Statement of Design Acceptability by the EA on 13th December 2012, ONR reference EPR70475N [Ref 3]. This concluded the GDA process. This has a 10-year validity, and as stated above it is the intention of NNB GenCo (SZC) to re-validate this via the replication justification workstream.

8.2 The Justification Decision. As a requirement of European Law, specifically the Euratom Basic Safety Standards Directive, Member States need to consider whether classes or types of practice causing exposure to ionising radiation are justified, in terms of their overall economic, social or other benefits in relation to the health detriments they may cause.

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The Secretary of State for BEIS (formerly DECC) issued a legal instrument in accordance with the Justification of Practices Involving Ionising Radiation [Ref 8] in respect of the generation of electricity by the EPR Nuclear Reactor which is proposed to be constructed at the SZC site. The Justification Decision (Generation of Electricity by the EPR Nuclear Reactor) Regulations 2010 SI No. 2844, states: “By these Regulations the Secretary of State made a justification decision in accordance with the Justification of Practices involving Ionising Radiation Regulations 2004. The 2004 Regulations implement Article 6(1) and (2) of Council Directive 96/291 Euratom laying down basic safety standards for the protection of health of workers and the general public against the damage arising from ionising radiation.”

8.3 Government Siting Policy The National Policy Statement for Nuclear Power Generation (EN-6), [Ref 9] issued by BEIS (formerly DECC) that was laid before parliament on 23 June 2011 includes Sizewell as one of eight sites found to be potentially suitable for the development of new nuclear power stations by 2025. NNB GenCo (SZC) intends to commence construction activities before this date. ONR have confirmed to BEIS that the Sizewell site passed the demographic criterion in the Strategic Siting Assessment that underpins the inclusion of Sizewell in EN-6. There have been no significant demographic changes in the local area since 2011 that would invalidate this judgement. A Development Consent Order (DCO) application for the site was made on 27th May 2020.

8.4 Development Consent Order NNB GenCo (SZC) has applied to PINS seeking development consent to use the SZC site for a new nuclear plant pursuant to the Planning Act 2008 (which supersedes the corresponding provisions of section 36 of the Electricity Act 1989).

8.5 Environment Agency Permits and Authorisations Under the Environmental Permitting Regulations (England and Wales) 2016 (as amended), Sizewell C requires three operational environmental permits, granted by the Environment Agency (EA) to operate the Power Station. These are:  Water Discharge Activity (WDA) Permit - Required to allow the discharge of non-radioactive cooling water from the Sizewell C reactor back into the sea.  Combustion Activity (CA) Permit - Required to allow the operation of the diesel generators in the unlikely event the power station experiences a loss of onsite power.

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 Radioactive Substances Regulation (RSR) Permit - Required to allow the discharge of small amounts of radioactivity from the Sizewell C reactor into the air and sea, and off-site disposal of solid radioactive waste generated by the reactor. NNB GenCo (SZC) submitted applications to the EA for the three operational permits at the same time as the development consent application. These are currently going through determination and are to be granted prior to the award of the Development Consent Order (DCO).

8.6 Article 37 of the Euratom Treaty on Radioactive Waste Disposal At the point of the submission of the DCO and three operational environmental permit applications, the United Kingdom was within a transition period for exiting the European Union and Euratom Treaty. During this period the UK is required to to meet its obligations to the union and under the treaty. Under Article 37 of the Euratom Treaty, BEIS on behalf of UK Government is required to submit sufficient information concerning the proposed development at Sizewell in relation to the generation and disposal of radioactive waste. This is to enable the European Commission to give its opinion on whether such a development is likely to result in the radioactive contamination of the water, soil or airspace of another member state. NNB GenCo (SZC) has supplied an Article 37 submission to BEIS on the proposed development at SZC, for onwards transmission to the European Commission post Ministerial Sign Off. Before SZC can be granted an environmental permit under RSR, it is necessary for the BEIS to secure an opinion from the European Commission under Article 37 of the Euratom Treaty.

8.7 Department for Transport Dangerous Goods Division The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 implements the international requirements for transport of hazardous goods by road and rail. This harmonised the standards for the safe transport of dangerous goods within and between member states and are closely based on the requirements of the IAEA Safety Standards ‘Regulations for the Safe Transport of Radioactive Material’ – SSR-6. As part of the Construction, Commissioning, Operation and Decommissioning of SZC, NNB GenCo (SZC) will need to move radioactive material and nuclear matter to and from the site and radioactive waste from the site. An assessment of the radiological impacts from such movements was assessed as part of the SZC planning application. All movements will be undertaken within the relevant regulatory requirements under the CDG, and Ionising Radiations Regulations 2017.

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SZC will prepare and submit any required applications or notifications to the ONR prior to radioactive material or nuclear material being received on site.

8.8 Article 41 of the Euratom Treaty on Nuclear Activities As previously mentioned, the UK is currently in a transition period for exiting the Euratom Treaty. During this period the UK is obligated to continue to meet the requirements set out under the treaty. Under Article 41 of the Euratom Treaty SZC is required to submit information on the proposed new nuclear investment at Sizewell to the European Commission. The European Commission verifies that the objectives set in the Euratom Treaty are respected, in terms of nuclear and radiation safety and safeguarding of nuclear materials. SZC formally made a submission to the European Commission in July 2019, which is currently being assessed. It should be noted that most of the nuclear and radiation safety requirements established within the Euratom Treaty have been implemented within UK domestic legislation, and as such post the transition period these requirements will remain in place. New legislation covering nuclear safeguards is in place and operating under shadow arrangements. These will formally come into effect post the UK exiting the European Union and Euratom. NNB GenCo (SZC) will work with the ONR CNSS in the application of these requirements.

8.9 Funded Decommissioning Programme and Decommissioning Strategy Under the Energy Act 2008, an operator of a new nuclear power station must obtain the approval of the Secretary of State for a Funded Decommissioning Programme (FDP). The FDP ensures that decommissioning has been incorporated within the design and construction of a new build nuclear power station and that it has secure financing arrangements in place to meet the full costs of decommissioning once the power plant ceases generation. The Funded Decommissioning Programme (FDP) consists of two key documents:  Decommissioning Waste Management Plan (DWMP) - This details how the reactor site will be decommissioned, along with a robust cost estimate for undertaking that decommissioning and management of the associated waste.  Funding Arrangement Plan (FAP) – This details the financing arrangements for generating the required funds to meet the full costs of decommissioning the reactor site. With both HPC and SZC plants being similar in design this has allowed for a common decommissioning approach to be applied across both sites which has revealed several benefits including:  SZC will undergo decommissioning shortly after HPC which provides the opportunity for lessons learned from HPC to be directly applied to SZC reducing risk.

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 Tools, Experience and Skills developed for HPC can be reused at SZC affording greater efficiency and savings to be realised.  Economies of scale across both sites will minimise both risk and costs and ensure that proven practices and approaches are employed. NNB GenCo (SZC) will be submitting a Funded Decommissioning Programme (FDP) for SZC to BEIS for approval pursuant to Section 45 of the Energy Act 2008, using the HPC FDP as a basis. It is expected that an approved FDP will be in effect prior to commencement of construction. The SZC DWMP will build on the information presented in the approved 2014 HPC DWMP, updating the information to the latest design configuration and taking account of the site-specific differences at SZC. This will be consistent with the requirements of Licence Condition 35. The decommissioning strategy to be employed by NNB GenCo (SZC) is set out in NNB GenCo (SZC)’s EPR Corporate Decommissioning Strategy and Plan. The basic objectives are:  To ensure the continued safety of the public, the workforce, and the environment,  To minimise the environmental impact of the station as far as reasonably practicable.  To decommission the station as soon as it is reasonably practicable to do so, taking account of all relevant factors,  To release land for other use as appropriate; and  To minimise the expenditure of resources on decommissioning. The preferred decommissioning strategy selected for SZC is Early Site Clearance. Decommissioning will commence as soon as possible after End of Generation (EoG) at the site. Decommissioning will continue until all parts of the power generation plant are removed and the site cleared so that it could be released from NSL requirements. The Spent Fuel Interim Storage Facility will remain in operation on the site for a period of about 60 years after EoG, after which it too will be decommissioned, and the site cleared. It is assumed that for this twin reactor site, Unit 2 will shut down 18 months after Unit 1. The Early Site Clearance strategy reflects the determination that the technical constraints and complexity of decommissioning an EPR site are not significantly reduced by delaying decommissioning or by periods of safe storage. International guidance and experience typically support this approach and has shown that Pressurised Water Reactors (PWR) reactors can be decommissioned on such a timeframe without the need for an extended period of deferral to allow radioactive decay. The Spent Fuel Interim Storage Facility and the Intermediate Level Waste (ILW) Interim Storage Facility will only be decommissioned once they have been emptied of spent fuel and radioactive waste.

8.10 Security Plan. NNB GenCo (SZC) is developing a conceptual security plan and a construction security plan in accordance with the ONR published SyAPS [Ref 10]. NNB GenCo (SZC) will make these plans available for approval by the ONR Civil Nuclear Security and Safeguards (CNSS). Additionally, NNB GenCo (SZC) will develop

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phased amendments to the security plan for various milestones during construction and commissioning. For example, six months prior to initial receipt of nuclear fuel, NNB GenCo (SZC) will submit an amendment to the approved security plan applicable to fuel receipt and storage available for approval by ONR (CNSS). NNB GenCo (SZC) will make a final security plan available to ONR (CNSS) for approval prior to the commencement of operation of the first reactor.

8.11 Safeguards. The Euratom Treaty sets out the requirements for its member states in relation to nuclear safeguards. At the time of the writing this Nuclear Site License Application the UK is within a transition period for exiting the Euratom Treaty. During this period, the UK is required to continue to meet its obligations under the treaty. These measures verify that countries comply with their international obligations on nuclear materials accountancy and do not use nuclear materials from their civil nuclear programmes to manufacture nuclear weapons. New legislation and arrangements covering nuclear safeguards is in place in the UK and will formally come into effect post the UK exiting the European Union. NNB GenCo (SZC) will be providing the ONR (CNSS) with preliminary information on its nuclear safeguards measures to verify that nuclear material is properly accounted for and is not diverted to undeclared uses. Those measures include nuclear material accountancy, containment, and surveillance. Full arrangements will be developed and be in place before fuel delivery.

8.12 Emergency Plan In addition to the onsite emergency plan under LC 11, NNB GenCo (SZC) will comply with the Radiation Emergency Preparedness and Public Information Regulations 2019 (REPPIR 2019) [Ref 11]. The generation of the offsite plan under REPPIR 2019 is the responsibility of the local authority supported by information provided by a licensee. NNB GenCo (SZC) will work with the local authorities to ensure that they have appropriate offsite emergency plans that cover SZC. Currently, there are offsite emergency plans for SZA and SZB, and NNB GenCo (SZC) anticipates that offsite emergency planning for SZC will be covered by the same plan that is used for SZA and SZB, modified as necessary to account for SZC. Prior to the start of operation, SZC will be required to carry out a Hazard Evaluation and Consequence Assessment and provide a Consequence Report to the local authority and to the ONR, recommending a minimum technical distance for a Detailed Emergency Planning Zone (DEPZ). The local authority will, based on this material and having considered local factors, determine whether there needs to be any alteration to the DEPZ and Off-Site Plan prior to commencing operation of the plant. ONR will provide independent oversight in this process.

APPENDIX A

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Reference for ONR Supporting Evidence Requested by ONR guidance Application Section Guidance Part 2- Embodied in A safety management prospectus including the 1,2 Company Manual nuclear baseline Part 1, Head A description of the installation and activities to be 1,2 Document Section 5 licensed Part 1, Head A statement confirming that the operation of the 1,2 Document Section power station is ‘Justified’ as required by the 8.2 Justification of Practices Involving Ionising Radiation Regulations 2004 Part 6 A map of the site showing its proposed location and 1,2 the proposed boundary of the area to be licensed, with details of the local demographics Part 1, Head If the power station design has been subjected to a 1 Document Section Generic Design Assessment, a verification that the 6.1 specific site is bounded by the site envelope specified in the Design Acceptance safety case. Part 1, Head A demonstration of conformity with any UK 1 Document Section 7 Government siting policies and requirements Part 1, Head Details of the ownership of the site or arrangements 1,2 Document Section 6 for its leasing, and the proposed arrangements for achieving security of tenure for the licensee Part 4 Licence condition compliance statements and top- 1,2 tier arrangements. Part 1, Head The submission or review of adequate safety cases 1,2 Document Section forming the Pre-Construction Safety Report 7.4 Part 1, Head Document A statement of decommissioning arrangements. 1 Section 8.9 Part 4 LC11 Details of appropriate emergency arrangements and 1 Part 1, Head a suitable emergency plan. This may be limited in Document Section extent before nuclear fuel is brought onto the site. 8.12 Part 4 LC35

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Reference for ONR Supporting Evidence Requested by ONR guidance Application Section Guidance Part 3, Terms of reference for the licensee’s Nuclear Safety 1,2 Committee. Part 1, Head Briefing on the history of the site and an assessment 2 Document Section of its suitability for the proposed development in 6.1 and PCSR to be relation to all the Safety Assessment Principles submitted to ONR relevant to siting.

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APPENDIX B CORPORATE STRUCTURE OF NNB GENCO (SZC)

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NNB GENERATION COMPANY (SZC) LTD

COMPANY DOCUMENT

GLOSSARY OF TERMS

© 2020 Published in the United Kingdom by NNB Generation Company (SZC) 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 GenCo, 90 Whitfield Street, London, W1T 4EZ. The electronic copy is the current issue and printing renders this document uncontrolled.)

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1 INTRODUCTION

ACF Areva Creusot Forge ACWP Actual Cost of Work Performed AIL Abnormal Indivisible Load ALARP As Low As Reasonably Practicable AD Associated Developments ADDIE Analysis, Design, Development, Implementation, and Evaluation – the systematic approach to training AF Assessment Finding AFR Accident Frequency Rate B

BAFO Best And Final Offer - final version of a tendered sum once a review of all tender clarifications/further information release has taken place. BAT Best Available Technique BCWP Budgeted Cost of Work Performed BCWS Budgeted Cost of Work Scheduled BDR Basic Design Reference BEIS The Department for Business, Energy & Industrial Strategy (The Department for Business, Innovation and Skills (BIS) and the Department of Energy and Climate Change (DECC) merged to form BEIS. BL Baseline BNI Balance of Nuclear Island - this is the infrastructure that is outside of the reactor building BoD Basis of Design BOP Balance of Plant BPE Bon por execution (Fit for use) BTR Book of Technical Requirements BTS Book of Technical Specifications

CAD Computer Aided Design CCIS Consolidated Change Information System - CCIS is a tool to manage the construction change processes in order to facilitate a swift and effective decision making process. CDM Construction (Design and Management) CDM-C Construction (Design and Management) Co-ordinator CES Construction Electrical Supplies CfD Contract for Difference

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CFT Cold Functional Test CGN China General Nuclear Power Group CI Conventional Island CI-BOP Conventional Island – Balance of Plant CMF Change Management Form CNEN Centre National d’Equipment Nucleaire CNEPE Centre National d’Equipment et de Production d’Electricite CNI Chief Nuclear Inspector COD Commercial Operation Date Common Raft The concrete base that sits beneath the reactor, the fuel store and the safeguarding buildings COTS Commercial Off The Shelf CP Current Plan CPT Cone Penetration Test CRF Circuit de Refroidissement – Cooling Water Circuit CSJ Construction Safety Justification CTP Commissioning Test Pack

DA Design Authority DAC Design Acceptance Certificate DACC Design Assurance Co-ordination Committee DAPI Domaine d'Achats Production Ingénierie – EDF Procurement. DCC Delivery Command Centre DCO Development Consent Order DDR Decided Design Reference DIPNN Division Ingenierie Projet Nouveau Nucleaire DEGB Double Ended Guillotine Break DQP Design Quality Plan DRI Installation Rules DSR Design Substantiation Report DTS Delivery To Site

EA Environment Agency EAM Enterprise Asset Management EAU Employee Affairs Unit ECI Early Contractor Involvement ED Engineering Directorate

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EAI Electrical All Island ECI Early Contractor Involvement EDF Électricité de France EDF SA EDF Societe Anonyme – EDF Group EDG Emergency Diesel Generators EDP Engineering Management Meeting EDR Engineering Design Ready EDRMS Electronic Document and Records Management System ENG EDF Engineering Rules EPCC Engineering, Procurement, Construction and Commissioning EPCC Emergency Planning Consultative Committee EPR Environmental Permitting Regulations EPR Trade marked for European Pressurised Reactor EAC Estimate at Completion ETC-C EPR Technical Code – Civil ETC-F EPR Technical Code – Fire Euratom The European Atomic Energy Authority EV Earned Value EVM Earned Value Management EWC Early Works Contract EWN Early Warning Notice ExV Expected Value

FA3 Flamanville 3 – new build EPR reactor in France. FAL Financial Authority Limit FID Final Investment Decision FIDD Final Investment Decision Date FMEA Failure Mode Event Analysis FRN Functional Requirements Note FTA Fault Tree Analysis FWA Forward Work Activities

GBP Pound Sterling GDA Generic Design Assessment GDF Geological Disposal Facility GenCo This is an oversight board, responsible for the governance of SZC.

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HAZOP HAZard and OPerability HD Building reference for the Emergency Diesel Building HF Building reference for the Electrical Building HFT Hot Functional Test HIPO HIgh POtential event HJA Building reference for the Auxiliary Transformer Building HKB Building reference for the Boron Storage HL Building reference for the Safeguard Building HLW High Level Waste – regarding radioactive waste HM Building reference for the Turbine Building HMI Human Machine Interface HoldCo The HoldCo SZC Board HP Hold Point HPC Hinkley Point C HPRD Hold Point Review Document HQA Building reference for the Waste Storage Building HQB Building reference for the Waste Processing Building HR Human Resources HR Building reference for the Reactor Building HSE Health and Safety Executive HVAC Heating, Ventilation and Air Conditioning HVL Building reference for the Hot Laundry Building HW Building reference for the Access Building

I&C Instrumentation & Control (aka C&I) IACO Independent Assessment, Challenge and Oversight IAEA International Atomic Energy Agency IBR Integrated Baseline Review IC Intelligent Customer IDR Implemented Design Reference IED Miscellaneous Electrical Facilities – small power, lighting, IT and communications IED Improvised Explosive Device IEG General Electrical Facilities – main electrical supply system ILW Intermediate Level Waste – regarding radioactive waste IMS Integrated Management System INA Independent Nuclear Assurance INPO Institute of Nuclear Power Operations

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IPA Infrastructure Projects Authority IR Industrial Relations ISFS Interim Spent Fuel Store ITA Independent Technical Assessment ITP Inspection & Test Plan ITT Invitation To Tender IUK Infrastructure United Kingdom IWS Integrated Work Schedule

J0 Jour 0 (Day 0) – First pour of Nuclear Island Concrete

KPI Key Performance Indicators

LC Licence Condition LCCC Low Carbon Contract Company LD Liquidated Damages LE Latest Estimate LLW Low Level Waste – regarding radioactive waste LMS Learning Management System LOD List Of Deliverables LR Learning Report LTI Lost Time Injury LTQR Lifetime Quality Record

M&E Mechanical & Electrical MCR Main Control Room MCW Main Civil Works MDT Multi-Disciplinary Team MED Management Expectations Document MEH Mechanical, Electrical & HVAC MEPM Monthly Engineering Project Meeting MEWP Mobile Elevated Work Platform MODEM Monitoring and Decision Meeting

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MoU Memorandum of Understanding MSW Managed Service Worker MTP Medium Term Plan

NCR Non-Conformance Report NDT Non-Destructive Testing NEDA Nuclear Engineering Degree Apprentices NELS Nuclear and Environmental Licensing and Security NG National Grid NGET Nuclear Generation Executive Team NI Nuclear Island NIC Nuclear Industry Council NIC Nuclear Island Concrete NNB Nuclear New Build NNB GenCo Nuclear New Build Generation Company Limited NPE Nuclear Pressure Equipment NPS Nuclear Pressure System NRE Nuclear Reportable Event NSAN National Skills Academy (Nuclear) NSDAP Nuclear Safety Design Assessment Principles NSSS Nuclear Steam Supply System NTP Notice to Proceed

OE Owners Engineering OHL Overhead Lines OIM Offshore Installation Manager OL3 Olkiluoto 3 – new build EPR reactor in Finland. OLIM Organisational Learning – Database ONR Office for Nuclear Regulation ONR-CNSS Office for Nuclear Regulation – Civil Nuclear Security and Safeguards OPEX Operational Experience

PAS Permanent Aggregate Store PCSR Pre-Construction Safety Report

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PDM Programme Delivery Model PDMS Plant Design Management System – for producing 3D Computer Aided Design models) PEP Project Execution Plan PLM Project (or Product or Plant) Lifecycle Management PMA Project Managers Assessment PMB Performance Management Baseline PMO Project Management Organisation POSR Pre-Operational Safety Report PPE Personal Protective Equipment PQP Project Quality Plan PRIO Project Risks, Issues and Opportunities PRODEM PROcurement Decision Meeting PRR Project Review Report PSA Probabilistic Safety Assessment PSR Periodic Safety Report PV Planned Value

QA Quality Assurance QC Quality Control QCRA Quantitative Cost Risk Assessments QDS Quarterly Data Summary QRA Quality Related Activities QSRA Quantitative Schedule Risk Assessments

R&A Review and Acceptance RAMS Risk Assessment & Method Statement RC1 Reference Configuration 1 (and subsequent updates e.g. RC1.2) RC2 Reference Configuration 2 RCA Root Cause Analysis RCC-E Regles de Conception et de Construction des Materials Electriques – Design and Conception Rules for Electrical Components RCC-M Regles de Conception et de Construction des Materials Mechaniques – Design and Conception Rules for Mechanical Components RCn Reference Configuration n – ‘n’ refers to the number in sequence e.g. RC1, or RC2 etc. RD Responsible Designer

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RDR Ready Design Reference RFT Right First Time RIDDOR Reporting of Injuries, Diseases and Dangerous Occurrences Regulations RMI Reflective Metallic Insulation ROTC Risk, Opportunity, Trend and Change RP Resolution Plan RPA Radiation Protection Advisor RPE Respiratory Protective Equipment RPE Nuclear Island vent and drain system RPV Reactor Pressure Vessel RSR Radioactive Substances Regulations RWA Radioactive Waste Advisor

SAT Systematic Approach to Training SC Safety Case SCC Systems, Structures & Components SCC Site Command Centre SDM System Design Manual SELMa Safety & Environment Learning Management SG Steam Generator SG Safeguard SMS Safety Management System SNC Start of Nuclear Cleaning SNI Sensitive Nuclear Information SOC Signature Of Contract SoDA Statement of Design Acceptability SQEP Suitably Qualified and Experience Person SQIMP Supply Chain Quality Improvement Plan SWITCH A digital platform for managing engineering procurement, construction and commissioning processes SZA Sizewell A- decommissioned Magnox Reactor SZB Sizewell B- operating PWR, EDF NG ltd SZC Sizewell C – Proposed twin unit PWR

TBM Tunnel Boring Machine TEP Effluent Coolant Storage & Treatment

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TEU Liquid Waste Treatment System TG Turbine Generator TR Technical Review TRIR Total Recordable Incident Rate TSN Taishan – Operational EPR reactor in China

U1 Unit 1 - the first reactor U2 Unit 2 - the second reactor UNICORN UNiversal I&C platfORm for Nuclear – this is the name of a hardware based Instrumentation & Control (I&C) platform.

VDR Virtual Data Room VLLW Very Low Level Waste – regarding radioactive waste VMS Visitor Management System VMU Vehicle Maintenance Unit

WANO World Association of Nuclear Operators WENRA Western European Nuclear Regulators’ Association

YTD Year To Date

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NNB GENERATION COMPANY (SZC) LTD

COMPANY DOCUMENT

COMPANY MANUAL- SIZEWELL C

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TABLE OF CONTENTS

1 INTRODUCTION ...... 5 1.1 References and Definitions ...... 6 1.2 Bibliography...... 7

2 THE COMPANY- NNB GENCO (SZC) ...... 9 2.1 Company Overview ...... 9 2.2 NNB GenCo (SZC) Vision and Values ...... 9 2.3 Our Values & Ambitions ...... 9

3 THE UK EPR FOR SIZEWELL C...... 12 3.1 Sizewell C Site ...... 12 3.2 Security of Tenure ...... 13 3.3 Basic EPR Description ...... 14

4 NNB GENCO (SZC) COMPANY DETAILS ...... 15 4.1 General Overview ...... 15 4.2 Funding Arrangements ...... 15 4.3 Links with EDF, EDF SA and CGN ...... 16 4.4 The NNB GenCo (SZC) and NNB HoldCo (SZC) Boards ...... 16 4.5 Board Membership & Responsibilities ...... 18 4.5.1 Managing Director ...... 18 4.5.2 Engineering and Delivery Director ...... 19 4.5.3 Financing and Economic Regulation Director ...... 19 4.5.4 Finance Director ...... 20 4.5.5 General Counsel and Company Secretary ...... 20 4.5.6 Safety, Security and Assurance Director ...... 21 4.5.7 Human Resources Director (post FID) ...... 22 4.5.8 Pre-Operations Director (Post FID) ...... 22 4.5.9 Non-Executive Directors ...... 23 4.6 Board Meetings ...... 23 4.7 Delegated Authority ...... 23 4.8 Sub-Committees ...... 24

5 ORGANISATIONAL CAPABILITY ...... 24 5.1 Staffing ...... 24 5.2 Nuclear Baseline ...... 25

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5.3 Control of Organisational Change ...... 27 5.4 UK EPR intellectual property ...... 27 5.5 Transfer of know-how and lessons learned ...... 28 5.6 Supply Chain Strategy ...... 28

6 SAFETY GOVERNANCE ...... 28

7 ENVIRONMENTAL PERMITS ...... 31 7.1 Overview...... 31

8 PROJECT PHASING ...... 32 8.1 Sizewell C Hold Points ...... 34

9 SZC SITE ORGANISATION (AROUND FID) ...... 35 A.1 Sub-Committees ...... 37 A.1.1 Sizewell C (SZC) Project Board ...... 37 A.1.2 Organisation & Development Committee ...... 37 A.1.3 Nuclear Safety Committee (NSC) ...... 38 A.1.4 Independent Advisory Committee ...... 39 A.1.5 Environmental Sustainability Committee (ESC) ...... 39 A.1.6 Operational Development Committee (ODC) (Post-FID) ...... 39 A.1.7 Safety, Health and Environment Committee (SHEC) (Post-FID) ...... 40 A.2 Design and Licensee Roles...... 41 A.2.1 Intelligent Customer (IC) Capability ...... 41 A.2.2 Responsible Designer ...... 42 A.2.3 HPC and EDF Support...... 43 A.2.4 Technical Client Organisation (TCO) ...... 43

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1 INTRODUCTION

This company manual has been prepared by NNB Generation Company (SZC) Limited to describe the organisation and management of the company and also constitutes the management prospectus to support the application for a Nuclear Site Licence (NSL), Radioactive Substances Regulation permit, Water Discharge and Combustion Activity permits for the installation and operation of two EPR nuclear power reactors at Sizewell in Suffolk. It is intended that the Sizewell C EPRs will be identical to the plant under construction at Hinkley Point C, with minimal changes being made to address local site issues and learning from HPC construction. This will allow NNB GenCo (SZC) to maximise the nuclear knowledge, technical expertise, safety and commercial benefits from replication and from the Generic Design Assessment (GDA) and Best Applicable Techniques (BAT) processes. The manual shows how the organisation and appropriate governance, oversight and control arrangements in place are appropriate now (and will be developed in the future as the project progresses), to assure all aspects of safety, (Nuclear, Environmental and Industrial), and also an effective company organisation. It is intended that NNB GenCo (SZC) will be the nuclear site licensee and environmental permit holder for the site. A Nuclear Baseline document [Ref 1] identifies nuclear and environmental safety related roles and sufficient, competent resources will be available at the right time to fulfil these roles and for the company to be and maintain its status as an intelligent customer as the organisation develops. This manual describes the vision of the company, gives a brief description of the facility, describes the company organisation, organisational capability, safety, and environmental governance and permitting. This company manual will be reviewed periodically and revised to fully reflect the requirements of the post-final investment decision organisation and shareholding, construction, commissioning and later for full operation. The company manual demonstrates that NNB GenCo (SZC) 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.

Image 1: Projected SZC to the North of the existing SZB

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1.1 References and Definitions

Ref Title Location Document No. 1 NNB GenCo (SZC) Nuclear Baseline EDRMS 100200200 2 Licensing of nuclear installations; Sept. 2019 ONR Website http://www.onr.org.uk/licensing- nuclear-installations.pdf 3 ONR – The processing of Licence applications for ONR Website http://www.onr.org.uk/operational/ new nuclear sites, NS-PER-IN-3 Issue 5. assessment/ns-per-in-003.pdf 4 Radioactive Substances Regulation: EA Website https://assets.publishing.service.gov Management Arrangements at Nuclear Sites – .uk/government/uploads/system/up Version 2 – Environment Agency loads/attachment_data/file/299652 /RSR_Management_arrangements_ at_nuclear_sites.pdf 5 Radioactive Substances Regulation – EA Website https://assets.publishing.service.gov Environmental Principles, The Environment .uk/government/uploads/system/up Agency Version 2.0 loads/attachment_data/file/296388 /geho0709bqsb-e-e.pdf 6 Guidance on the Production and Use of an EA Website https://assets.publishing.service.gov Integrated Management Prospectus – .uk/government/uploads/system/up Guidance Note – Radioactive Substances loads/attachment_data/file/296430 Regulation – HSE and Environment Agency. /geho0709bqwx-e-e.pdf 7 Licensee use of contractors and intelligent ONR Website http://www.onr.org.uk/operational/ customer capability tech_asst_guides/ns-tast-gd-049.pdf T/AST/049 – Rev 6 – ONR 8 NNB GenCo (SZC) Nuclear Safety Policy EDRMS 100200165

9 NNB GenCo (SZC) Health and Safety Policy EDRMS 100200168

10 NNB GenCo (SZC) Environmental Policy EDRMS 100200170

11 NNB GenCo (SZC) Quality Policy EDRMS 100200187

12 NNB GenCo (SZC) Resourcing Strategy EDRMS 100196816 – Issue 1, 13 NNB GenCo (SZC) Company Procedure – Define, EDRMS NNB-209-PRO-000025 Manage and Release Key Hold Points. 14 NNB GenCo (SZC) Management System Manual EDRMS 100200202 15 Sizewell C- Nuclear Safety Committee Terms of EDRMS 100197655 Reference.

16 UK Strategy for Radioactive Discharges 2009 HMG Website https://assets.publishing.service.gov. uk/government/uploads/system/upl oads/attachment_data/file/249884/ uk_strategy_for_radioactive_dischar ges.pdf 17 Shareholders Agreement EDRMS Contact Company Secretary.

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1.2 Bibliography.

Ref Title Location Document No.

ONR – NSD Safety Assessment Principles for http://www.onr.org.uk/saps/saps20 ONR Website 14.pdf 1 nuclear facilities, 2006. http://www.onr.org.uk/operational/te ONR-Function and content of a safety ch_asst_guides/ns-tast-gd-072.pdf 2 management prospectus. T/AST/072 rev 3 ONR Website

http://www.onr.org.uk/operational/te ONR-Licensee design authority capability ch_asst_guides/ns-tast-gd-079.pdf 3 T/AST/079 – Issue 1 – ONR ONR Website

http://www.onr.org.uk/operational/te ONR - Procurement of nuclear safety related ch_asst_guides/ns-tast-gd-077.pdf 4 items or services T/AST/077 ONR Website

Term / Abbreviation Definition BAT Best Available Technique BEIS Government Department of Business Enterprise and Industrial Strategy BS British Standard CAP Corrective Action Plan CNS Civil Nuclear Security DA Design Authority DAC Design Acceptance Confirmation DCO Development Consent Order DIPNN Division Ingénierie Projet Nouveau Nucléaire, The engineering division of EDF SA EA Environment Agency EDF Energy Nuclear Generation Limited, Company Number 03076445 Barnett Way, Barnwood, EDF Energy Nuclear Generation Ltd Gloucester, GL4 3RS,

EDF SA Electricité de France Société Anonyme EDRMS Electronic Document and Record Management System EDVANCE An engineering support company, jointly owned by Framatome and EDF SA. EPR The Pressurised Water Reactor developed and trademarked by Framatome (EPR™) EPROOG EPR Operators Owners Group- Forum for the exchange of OPEX on EPR construction, commissioning and operation. Export Controls Rules and regulation regarding to transfer of knowledge over borders. FDP Funded Decommissioning Programme FID Final Investment Decision FWP Forward Work Plan GDA Generic Design Assessment HPC Hinkley Point C HR Human Resource HSE Health and Safety Executive IAC Independent Advisory Committee; a sub-committee of the NNB GenCo (SZC) Board IACO Independent Assessment, Challenge and Oversight IAEA International Atomic Energy Agency IC Intelligent Customer IEC International Electro-Technical Commission IMS Integrated Management System

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INPO Institute of Nuclear Power Operators IPC Infrastructure Planning Commission IPSA Inter-Project Services Agreement; the arrangement pursuant to which people resource is shared between HPC and SZC. IS Information System ISO International Standards Organisation ITA Independent Technical Assessment KM Knowledge Management KPI Key Performance 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 (SZC) NNB Generation Company (SZC) Limited, Company Number 9284825 NNB HoldCo (SZC) NNB Holding Company (SZC) Limited, Company Number 9284571 NSC Nuclear Safety Committee NSIP Nationally Significant Infrastructure Projects NSL Nuclear Site Licence OCC Operational Control Committee OHSAS Occupational Health and Safety Management System ONR Office for Nuclear Regulation ONR CNSS Office for Nuclear Regulation Civil Nuclear Security and Safeguards. OPEX Operating Experience PCER Pre-Construction Environmental Report PCSR Pre-Construction Safety Report PDO Project Delivery Organisation 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 SZA Sizewell A SZB Sizewell B SZC Sizewell C TSO Technical Services Organisation, operating out of EDF Energy (TSO) Limited UK United Kingdom WANO World Association of Nuclear Operators WENRA Western European Nuclear Regulators Association

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2 THE COMPANY- NNB GENCO (SZC)

2.1 Company Overview NNB Generation Company (SZC) Limited was incorporated on 28th October 2014 as a private limited company. NNB GenCo (SZC)’s company number is 09284825 and its registered office is at 90, Whitfield Street, London W1T 4EZ. NNB GenCo (SZC)’s business is “to undertake the SZC project including the generation and sale of electricity.” NNB GenCo (SZC) will be applying for a Nuclear Site Licence [Refs. 2, 3] and relevant environmental regulatory permissions [Ref 4,5,6] for the purpose of construction and operation of a new build nuclear power plant consisting of two EPR units at Sizewell in Suffolk, the design of which has already achieved GDA approval. NNB GenCo (SZC) will enter into agreements with EDF SA, EDF and the HPC project to serve as the Responsible Designer (RD), and provide other project services. These agreements will enable NNB GenCo (SZC) to fulfil its responsibilities as a nuclear site licensee and environmental permit holder as an intelligent customer for those services. [Ref 7]

2.2 NNB GenCo (SZC) Vision and Values NNB GenCo SZC’s vision is “Building better energy together”, which is complimented by our mission of “Leading the way in building a fleet of safe, reliable nuclear power stations without costing the earth”.

2.3 Our Values & Ambitions Our values drive our operating principles and our objectives, and they are fundamental to the way we work. NNB GenCo (SZC) is committed to behaving in a safe and ethical manner and, through this, delivering excellent performance. Our Shareholders, consumers, Government, and the public place their trust in NNB GenCo (SZC) and expect us to work to build a safe, commercially successful, and financially robust business. The generation of reliable nuclear energy is a major contribution to the reduction of emissions produced in the UK to facilitate net-zero by 2050. It reduces our contribution to rising global temperatures. In setting a net zero target, the UK will be among a small group of countries handling climate change with appropriate urgency. The new target meets fully the requirements of the Paris Agreement, including the stipulation of ‘highest possible ambition’, and sets the standard for other developed countries as they consider their own pledges to the global effort. It is right that the UK takes a lead on this issue, and Sizewell C will provide a significant contribution in the battle against global climate change to date. There is the prospect of real benefits to UK citizens: cleaner air, healthier diets, improved health and new economic opportunities from clean growth. The creation of a low carbon, reliable electricity generation source at Sizewell, with the capacity of around 7% of the UK’s electrical energy provides a vital piece of the future infrastructure for the ambition of carbon neutral. We are committed to managing our environmental impacts to be as low as reasonably achievable, and Safety is our primary focus and in all cases within this document Safety includes; nuclear, radiological, industrial, environmental, health and security, unless in defining specific accountability or scope of an individual or committee. With this Safety focus in mind, we will increase the value of the business and make it a success. SZC will ensure that it meets the requirements of the Equality Act 2010 and non-discrimination against the nine protected characteristics, as well as celebrating and promoting the understanding and celebration of any difference.

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As the Project moves into the next phase of development, we will have a specific focus on building gender diversity to create the desired impetus for improved representation in the nuclear industry as reflected in the BEIS Sector Targets and in the NSSG Strategy:  40% of total workforce to be female by 2030 (taken to exclude the construction workforce)  50% of apprentices to be female by 2021  25% of senior management roles to be held by women by 2030 We will achieve success through conducting ourselves in accordance with our values and acting as one team, “Team SZC”. Our values provide a shared understanding of what is important to everyone at NNB GenCo (SZC).

 Humility: recognising there is always opportunity to learn from others and improve.  Positivity: being an ‘energizer’ and focussing on solutions when faced with challenges.  Respect: valuing people, safety, the environment and the rules under which we operate.  Clarity: Knowing how far we’ve come, how far we’ve got to go and how we’re going to get there.  Solidarity: Being one team, working closely together and helping each other.

NNB GenCo (SZC) is committed to a strong Safety culture, encompassing the following expectations:  Everyone is personally responsible for Safety.  Our leaders demonstrate a commitment to Safety.  Trust permeates the organisation.  Decision-making reflects Safety first.  Nuclear technology is recognised as special and unique.  A questioning attitude is cultivated.  Organisational learning is embraced.  Safety undergoes constant examination. Through a strong focus on these values and living up to our expectations the project will deliver the mission and achieve our ambitions:  To achieve zero harm to people.  To be the best and most trusted for customers.  To deliver safe, secure and responsible nuclear electricity.  To achieve strong financial and ethical performance.  To power society without costing the earth, and provide a major contribution to the net-zero economy.  To empower our people to be a ‘force for good’. The project will reinforce the mission and values through training programmes and performance management processes.

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The real engine of a great project is a team of skilled qualified and experienced people, motivated to work together with trust to the highest standards, not for themselves, but for the success for the project. The freedom for a team to succeed in nuclear construction:  has its foundation in project discipline process and clarity of purpose,  is a result of leadership at all levels; together with  concern for every individual. NNB GenCo (SZC) has defined its 10 core disciplines for a successful project which, with its annual priorities, give clarity on what NNB GenCo (SZC) will deliver: 1. Put Nuclear Safety first alongside industrial safety and the environment. 2. Be part of one team, one purpose and one incentive. The greater SZC project team, including contractors, will be bound by a common purpose, common incentive, strong supervision as well as quick open communication. 3. Start only when you are sure you won’t have to stop. The design process and the forward plan are linked to the nuclear safety case and procurement through equipment delivery and construction to first operation. If the design is late so is the project at every step. If the plan is not clear and deliverable the site will be disorganised. 4. Learn as much as possible from the experience of others. Through systematic training, innovation, and continuous improvement. Efficient construction and future operation require a design process that integrates experience from construction, operation, and innovation, particularly that of HPC.

5. Manage the risks created by interfaces. Interfaces between pieces of equipment, with buildings, between contracts and between teams require special attention. 6. Create realistic cost risk and time estimates. They are the foundation of the business case and are an essential input to procurement and project control. 7. Build as designed and document as built. The highest standards are needed to ensure there is no excuse for concessions, deviations are identified and resolved, and that equipment qualification and quality assurance are planned, managed and rigorous. The aim is that all work is right first time. 8. Embrace strong project control; it is the basic discipline of a project. No one can escape their responsibility to understand what they need to do; do what they said they would do, when they said they would do it, to the cost and quality required. 9. Every problem on site was caused much earlier and was avoidable. Early risk identification and forward planning allows pre-construction planners to plan, plan and plan again to mitigate risk and adapt to current realities, providing the construction team with a smooth

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workload. The construction team must be engaged inside the full project team and be proactive in identifying and resolving potential problems and learning from experience. 10. The client takes the risk on and off site and hence must be in control. The client must be able to be in control of people processes, machines and equipment; all through design and construction into operation. The NNB GenCo (SZC) Nuclear, Health and Safety, Environment and Quality Policies (Ref. 8, 9, 10,11,) explain that safety and care for the public, our workers and 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.

3 THE UK EPR FOR SIZEWELL C

3.1 Sizewell C Site NNB GenCo (SZC) intends to design, construct, commission, operate and decommission two UK EPR reactors on the SZC site, located at Sizewell, on the east coast of the County of Suffolk. It will be within the civil parish of Leiston cum Sizewell. (Figure 1. Below) The grid reference of the approximate centre of the SZC site. This is at grid references Lat.- 52.213200 Long.- 1.6162560SZC. The proposed site is located to the north of two existing nuclear installations, Sizewell B (SZB) and Sizewell A (SZA). SZB is a Pressurised Water Reactor operated by EDF Energy Nuclear Generation Ltd. SZA is a two-unit Magnox nuclear power plant now being decommissioned under the authority of the Nuclear Decommissioning Authority (NDA) with all nuclear fuel removed from site. The Sizewell C EPRs will be, wherever possible, a replica of the design approved by the GDA process and developed during detailed design of the sister plant under construction at Hinkley Point C. 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 and is the optimum method of reducing construction and operational risk. It combines the latest technologies to provide enhanced safety, environmental protection, technical and economic performance above those of existing reactors. An indicative layout plan (Figure 2) showing the boundary of the licensed site. The land that comprises the SZC nuclear licensed site is currently owned by EDF, and the land will be transferred at (or around) the final investment decision date. Nuclear Safety Cooperation Agreements will exist between NDA and Magnox Limited (the owners of Sizewell A), the Nuclear Decommissioning Authority and EDF Energy Nuclear Generation Ltd dealing with common issues relating to access, interactions, shared services and emergency arrangements; NNB GenCo (SZC) will become party to them. NNB GenCo (SZC) will have overall control of activities at the site throughout the construction period (and beyond). Ancillary support activities and buildings, such as offices for management, engineering and human resources, training simulator, maintenance facilities, warehouses, and storage facilities will also be on site. Other temporary laydown areas, offices and a public information centre may also be constructed just outside the licensed site boundary. Prior to the granting of the NSL other agreements and arrangements will be in place with EDF Energy Nuclear Generation Ltd to allow NNB GenCo (SZC) to undertake preliminary works on the SZC site.

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Figure 1. Location of Site.

Figure 2. Site Layout (Outer Green line shows NSL Boundary).

3.2 Security of Tenure The area of land that will be occupied by the proposed SZC station is currently owned by EDF Energy Nuclear Generation Ltd, and the land transaction will complete and ownership transferred at the time of the final investment decision (FID), so that the Nuclear Site Licence may be granted to NNB GenCo (SZC) as owner of the land. This land transaction will also include a transfer of some land which is part of the existing SZB Nuclear Licenced area which will ultimately become part of the Nuclear Site Licenced area of SZC. NNB GenCo (SZC) will own the freehold of the land from FID. Prior to ownership, NNB GenCo (SZC) will enter into an option agreement for this land.

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3.3 Basic EPR Description The SZC Site will have two UK EPR’s, each is a PWR with a rated thermal power of 4500 MW and an electrical power output of ~1630 MW depending on conventional island technology and heat sink characteristics. The EPR operating design life of 60 years, reduced fuel consumption and waste production per unit of energy output contributes significantly to energy production from a low carbon source. The design philosophy has the following objectives over earlier generations of PWR:  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 of fuel cycle lengths and capability for load following.  To give increased savings on uranium consumption per MWh produced.  To achieve further reduction in long-lived actinides generation per MWh through improved fuel management. The following list identifies the key structures contained within the EPR unit:  Reactor containment to house the nuclear steam-supply system.  Safeguard and electrical buildings are split into four divisions, (trains) each containing emergency systems with electrical support systems.  Fuel building.  Interim Spent Fuel Store.  Nuclear auxiliary building.  Diesel-generator buildings.  Effluent-treatment building.  Turbine hall containing the turbo-generator, condenser and ancillaries.  Conventional island electrical building.  Power-transmission and subsidiary feed platform.  Pumping station and the pre-discharge and discharge ponds.  Operational service centre, and  Gas and chemical storage building.

The detailed safety case for the EPR and its construction will be contained in the SZC Pre-Construction Safety Report (PCSR). Environmental Safety and Best Applicable Techniques are included in the RSR application for the station and its associated references.

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4 NNB GENCO (SZC) COMPANY DETAILS

4.1 General Overview NNB GenCo (SZC)’s sole purpose is to have responsibility for all activity related to the SZC project. NNB GenCo (SZC) is currently 100% owned by NNB HoldCo (SZC). NNB GenCo (SZC) will control all activities conducted under its Nuclear Site Licence and in compliance with environmental permits and other relevant safety, security, transport, and environmental legislation.

4.2 Funding Arrangements NNB GenCo (SZC) is currently funded via equity finance. Pursuant to the Shareholders’ Agreement [Ref. 17], EDF’s ultimate shareholding in Sizewell C is currently 80% and CGN’s ultimate shareholding is 20%. Shown in Figure 3 below.

Figure 3; Current Shareholding.

Equity financing for the SZC project is provided by way of the shareholders subscribing for further shares in NNB HoldCo (SZC) or by providing shareholder loans; the funds for which then flow down to NNB GenCo (SZC). Each shareholder provides equity financing to the SZC project pro rata to its percentage shareholding to fund the agreed SZC project budget. EDF intends to bring other investors into the SZC project at FID, and to retain a minority shareholding in SZC. It is anticipated that post-FID, the SZC project will be funded by a combination of equity and debt finance.

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Adequate financial resources will be made available to NNB GenCo (SZC) by its shareholders to enable the fulfilment of the Nuclear Site Licence, other Safety obligations and to maintain an organisation with appropriate skills, knowledge, and experience. The Shareholders’ Agreement and the other relevant project agreements support these requirements, and a new shareholder agreement and funding arrangements will be in place at FID for the NNB GenCo.

4.3 Links with EDF, EDF SA and CGN NNB GenCo (SZC) will be supported by NNB GenCo (HPC), EDF and EDF SA group companies and divisions, including EDF SA Division Ingénierie Projects Nucléaire Nouveau (DIPNN) and Edvance. The detailed design knowledge of the EPR has been built up over many years within the EDF SA group of companies and particularly within the DIPNN organisation. The use of a ‘single family’ approach provides a safety benefit by making use of this extensive expertise, while maintaining sufficient in-house expertise at NNB GenCo (SZC) to remain in control of the design integrity. Whilst for the sister plant of HPC, there was an “Architect Engineering” role, as the HPC plant is being replicated, the “Architect Engineering” role is incorporated in the “Responsible Designer” (See Appendix A2.2). Replication of the plant is the optimum approach to minimise risk- in design, construction and operation, and provide a project with commercial and safety risks “As Low as Reasonably Practicable”. (ALARP). NNB GenCo (SZC) will have control of activities being undertaken on its behalf and be an Intelligent Customer of the services provided. NNB GenCo (SZC) may, for some services and to aid replication, use the NNB GenCo (HPC) organisation to provide support, and will utilise the Technical Services Organisation (TSO) (see appendix A2.3.1) and all of the experience feedback and know-how of the HPC team, via formal agreements. Following granting of the NSL and any Environmental Permissions, changes to the organisation will be made using a Management of Change process in accordance with the NSL. Following a final investment decision to proceed with the SZC project, EDF, CGN (if CGN exercises its option to invest), and any other investors, will sign a Shareholders’ Agreement for the investment in two EPR reactors at SZC.

4.4 The NNB GenCo (SZC) and NNB HoldCo (SZC) Boards The NNB GenCo (SZC) Board is responsible for delivering a successful development of the SZC project, in a timely and efficient way meeting high safety and quality standards (subject to the HoldCo Board Reserved Matters, all of which must be brought to the NNB HoldCo (SZC) Board for resolution). The NNB HoldCo (SZC) Board is responsible for overseeing the strategy of the SZC project and approving the project’s development plan and budget. The NNB GenCo (SZC) 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.

NNB GenCo (SZC) 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 (SZC) with no other conflicts from other companies within the EDF Group. The NNB GenCo (SZC) Board retains the responsibility for Nuclear Safety decision making. The directors on the NNB HoldCo (SZC) Board are appointed by the shareholders in the SZC project, who have rights to appoint directors to the NNB HoldCo (SZC) Board based on their percentage shareholding. A shareholder may remove a director appointed by it by notice to NNB HoldCo (SZC) and appoint another director in his or her place.

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The NNB HoldCo (SZC) Board’s quorum requirements are set out in the Shareholders’ Agreement. Currently, as the largest shareholder in the project, EDF is responsible for the appointment of the Chairman and currently as the second largest Shareholder, CGN is responsible for the appointment of the Vice-Chairman of the NNB HoldCo (SZC) Board (although neither the Chairman or the Vice-Chairman has a casting vote on matters).

Figure 4 below shows the structure and membership of the NNB Holdco (SZC) Board.

Figure 4; NNB Holdco (SZC) Board

The directors of NNB GenCo (SZC), like all other directors in the UK, must act within their powers, in good faith, to promote the success of the company. The Directors must exercise independent judgement, exercising reasonable skill, care, and diligence. They must avoid conflicts of interest, comply with the Ethics & Business Conduct policy, and must declare interests in proposed transactions or arrangements with NNB GenCo (SZC). Each member of the NNB GenCo (SZC) Board is aware of these duties and is provided with periodic training to reinforce this. The NNB GenCo (SZC) Board is shown in Figure 5 below. All appointments of members of the NNB GenCo (SZC) Board and NNB GenCo (SZC)’s management must be consistent with the requirements of the licence documents and relevant regulatory guidance. The Shareholders’ Agreement acknowledges that all appointments of members of the NNB GenCo (SZC) Board and NNB GenCo (SZC)’s management must be consistent with the requirements of the nuclear site licence documents and relevant regulatory guidance. The NNB HoldCo (SZC) Board is responsible for the appointment and removal of the executive directors and the independent non-executive directors of the NNB GenCo (SZC) Board, following proposals made by the Chairman (or in some cases the joint proposal of the Chairman and Vice-Chairman) of the NNB HoldCo (SZC) Board.

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NNB GenCo (SZC) executive directors must have relevant experience for the role which satisfies an assessment against a set of agreed standards and competencies consistent with the Nuclear Baseline for SZC and which, when taken together with the rest of the NNB GenCo (SZC) Board, satisfies a collective assessment against such agreed standards and competencies. On appointment, NNB GenCo (SZC) Board members are made aware of their duties and are provided with periodic training to reinforce this and to ensure they are briefed on legal and regulatory developments relevant to their directorship. Each director receives an annual review to discuss their performance and consider their training and development needs.

Figure 5. NNB GenCo (SZC) Board NNB GenCo (SZC) also has a Company Secretary who attends all NNB GenCo (SZC) Board meetings and acts in an advisory role.

4.5 Board Membership & Responsibilities The individual responsibilities of the NNB GenCo (SZC) Board members are set out in the following sections.

4.5.1 Managing Director The Managing Director (MD) is appointed from amongst EDF’s Executive Directors. The MD acts as the Chairman of the NNB GenCo (SZC) Board and is a member of the Board of NNB HoldCo (SZC) and represents NNB GenCo (SZC) externally. The MD is accountable to the NNB GenCo (SZC) Board for NNB GenCo (SZC)’s compliance with all legislation including Safety legislation.

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A key role is ensuring the following areas are being satisfactorily achieved and monitored:  The NNB GenCo (SZC) Board has the right balance of membership to provide leadership, vision and independent challenge.  The NNB GenCo (SZC) Board sets the aims, strategy and policies and monitors performance by a set of improvement targets and key performance indicators (KPIs).  The NNB GenCo (SZC) Board receives the accurate, timely, high quality and clear information it needs to be effective; and  NNB GenCo (SZC) is interfacing well with its stakeholders and their views are being properly considered. The MD is responsible for the overall performance of the SZC project and leads the Executive Team, overseeing and monitoring the Executive Team to ensure that the following key goals are satisfactorily achieved:  NNB GenCo (SZC) operates safely and complies with legislative and regulatory requirements.;  Targets and performance standards are met, or effective corrective measures are put in place.  There is appropriate oversight and direction to management at all levels within the organisation.  Competent persons and other resources are provided throughout NNB GenCo (SZC); and  Appropriate internal control processes, including assurance arrangements, are in place to ensure high levels of efficiency, effectiveness, and Safety within NNB GenCo (SZC).

4.5.2 Engineering and Delivery Director The Engineering Director has responsibility for all aspects of the engineering and delivery. The Engineering Director is responsible for:  Management of the preparations for the construction of SZC site and related developments.  Managing any design changes and configuration control.  Oversight of Safety at the SZC site, related developments, and associated activities.  Ensuring environmental safety and monitoring on site.  Enabling works and relocating facilities from the existing SZB station.  Ensuring the RSR requirements for BAT are achieved and maintained.  Project management to safely deliver the SZC project preliminary and enabling works on schedule, to quality and on budget, and  Producing and continuously improving the monthly management reporting.

4.5.3 Financing and Economic Regulation Director The Financing and Economic Regulation Director’s key accountabilities are:  Commercial Structure; ensure NNB GenCo (SZC)’s commercial arrangements and financing activities are aligned with the shareholders’ investment strategy in SZC, and contribute to the development and implement of SZC financial strategies and policies, including agree with Government and investors and maintain the contractual and regulatory arrangements.

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 Investors; oversee the establishment of NNB GenCo (SZC)’s Investor Relations function, including putting in place systems and processes for the management of investor relations and maintaining a central depository for all shareholder related performance reporting (financial and non-financial), liaise with shareholder’s Investors Relationship teams and provide support in their external communication, including but not limited to communication to the financial market and rating agencies  Government interactions (national); liaise and work with the relevant Government departments, develop and present compelling Investment Cases, arrange appropriate governance and identify areas for optimisation, including funded decommissioning planning and waste management,  Liaison/interface of NNB GenCo (SZC) with legal, State Aid & other Consents  Lenders: deliver efficient processes and systems to ensure compliance with lending arrangements and enhance collaborative team working between NNB GenCo (SZC) and lenders;  Assure supply chain compliance with finance requirements,  External comms; be the focus for external communications

4.5.4 Finance Director The Finance Director is a shared director currently working on both HPC and SZC. responsible for;

 Building a financial model and implementing financial policies and strategies for NNB GenCo (SZC).  Primary interface with EDF Group Finance, including Interface/liaison with EDF Finance, e.g. Tax, treasury.  Financial governance and reporting; ensuring NNB GenCo (SZC) has a defined management information strategy and establishing robust financial and non-financial KPI reporting to monitor the delivery of business activities and initiate strategic business improvements.  Budget management: business plan and annual budget is prepared for the NNB GenCo (SZC) Board to review and approve as appropriate.  Providing construction cost estimates; developing an investment case to support decision making for the SZC programme.  Conducting independent financial and risk analysis to provide challenge to business development activities and undertake post-investment analysis of investment decisions to assess progress against strategies and plans.  Preparing annual accounts and reports as required by statutory and regulatory requirements, as well as the financial reports required by the Shareholders’ Agreement and any applicable IPA financing arrangements.  Deconsolidation/ Separation; prepare the company for deconsolidation and separation from the parent company,  Ensuring that Information Technology, Information Management Systems and Project Services for the organisation is effectively provided.

4.5.5 General Counsel and Company Secretary The General Counsel and Company Secretary is responsible for,

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 Serving as legal counsel to NNB GenCo (SZC), providing legal advice and support to NNB GenCo (SZC) across all aspects of the project; including legal arrangements for the supply chain, property matters, licensing and consents, financing and Government arrangements, and intellectual property.  Responsible for the development and continuous training of the lawyers within NNB GenCo (SZC)’s Legal department.  Ensuring NNB GenCo (SZC) complies with all relevant company law and regulation and operates to a high ethical standard,  Ensuring the Board and Board Committees within NNB GenCo (SZC) comply with legislative requirements and apply good corporate governance practice including meeting Companies Act requirements.  In consultation with the Chairman, preparing agendas for NNB GenCo (SZC) Board meetings and preparation of NNB GenCo (SZC) Board minutes, and  Receiving statutory instructions from the regulators on behalf of NNB GenCo (SZC), such as licence instruments made under the Nuclear Site Licence, or specifications made under the environmental permits.

4.5.6 Safety, Security and Assurance Director The Safety, Security and Assurance Director leads the Safety Directorate of NNB GenCo (SZC). This director is not a statutory director of the NNB GenCo (SZC) Board but has a right to attend the Board and speak on safety-related matters. This director has responsibility for:  Safety Reporting and Actions; Is a standing invitee to board meetings to discuss matters of Safety (Nuclear, Environment and Industrial).  Nuclear Safety: preparation, oversight and implementation of robust Nuclear Safety policies, provision of a strong assurance function within NNB GenCo (SZC) including independent assessment, challenge and oversight (IACO), ensuring that a Nuclear Safety Committee is established and operates effectively,  Industrial Safety; oversight of the implementation of processes and systems, management of the Safety, Health and Environment Committee, reporting to the board of safety matters.  Environmental impact: ensuring oversight of the RSR and other environmental permits to provide assurance that these permits are being respected, in terms of BAT and site monitoring, and the sustainability monitoring programme,  EA and ONR regulation; liaise and work with the regulators to ensure effective working between the parties,  Licensing, obtaining the permissions and relevant licences from the ONR, EA and any other related bodies, including those required on site for waste management and processing,  Quality: ensuring the project has appropriate levels of assurance (ISO 9001, ISO 14001, and performs audits to advise the board on any improvements.  Organisational Learning, the establishment of an effective and sustained learning process (OPEX) within NNB GenCo (SZC).  Security: liaison with the ONR (CNSS) and associated bodies to provide appropriate security vetting and physical arrangements, including cyber security and nuclear proliferation.

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 Pre-Ops – Manage the Pre-Operations aspects of the project as below, until appointment of the Pre- Operations Director.

4.5.7 Human Resources Director (post FID) The Human Resources Director is a shared director currently working on both HPC and SZC. This director is not a statutory director on the NNB GenCo (SZC) Board but is invited to the Board to speak on HR-related matters. This director has a Head of Function responsible for day to day management of:  HR Business Partnering; ensuring there is appropriate HR support to all line managers in NNB GenCo (SZC), providing advice, support, and coaching.  Resource planning & reporting; developing the NNB GenCo (SZC) human resource policies, Co-ordinating employee relations and pay issues.  Organisational design & Capability; developing and managing of the NNB GenCo (SZC)’s succession and resource planning and leadership development activities, ensuring that the NNB GenCo’s (SZC) 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 (SZC) organisational structure or resources which may affect Nuclear Safety.  Interface between HPC/SZC: on people & organisation & internal communications.  Skills, Education and Social Values, identify and develop a talent pipeline and ensure this meets organisational succession needs, chair the NNB GenCo (SZC) Skills Committee, and  Construction Workforce Development, looking ahead for training and recruitment of the workforce

4.5.8 Pre-Operations Director (Post FID) The Pre-Operations Director will be appointed post FID. Until that time the role will be carried out by the Safety, Security and Assurance Director. The Pre-Operations Director will have responsibility for:  Pre-operations involvement in review of all modifications.  Development of the SZC station operating model in terms of required organisation, standards, procedures, processes, etc.  Support the Nuclear Site Licence and environmental permitting forward work plan activities.  Both Nuclear Baseline and construction competency assessments, develop training programs, and deliver training to create a competent project staff.  The development of the organisational strategy, hiring plans and processes, and required training program descriptions for future station staff (operators, engineers, etc.).  Analysis and determination of the IT systems necessary to support configuration management and training learning management.  Perform and/or support integrated work schedule activities to achieve all SZC project milestones.  Development of an EPR operator family interface to receive learning from all future EPR commissioning and operations.

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 Development of the strategic nuclear fuel cycle design and implementation plans including acquisition, interim storage, and eventual disposal.  Development of the commissioning strategy, schedule, and processes to include use of operation’s personnel and turnover methodology.

4.5.9 Non-Executive Directors An important feature of the NNB GenCo (SZC) Board are its non-executive directors. It is intended to evolve the composition of the board from the current membership to expand to having more members with in-depth experience in key areas such as Construction and Nuclear Safety and provide advice and independent challenge to the NNB GenCo (SZC) Board. The NNB GenCo (SZC) Board currently comprises both independent and non-independent non-executive directors.

4.6 Board Meetings NNB GenCo (SZC) Board meetings take place every month unless the Board agrees otherwise. Meetings are usually held in the UK at NNB GenCo (SZC)’s registered office although the notice of the meeting may specify another venue. Directors can participate via telephone or video conference, if they can hear all of the other meeting participants and address other participants simultaneously. The working language of the Board is English. Notice of Board meetings, together with any supporting papers, will be given to Board members at least ten business days before the meeting is held. Quorum for a Board meeting is two directors (executive or non-executive), provided that one of the directors is a director that was nominated for appointment by EDF and one by GNI. If a quorum is not present, the meeting will be adjourned and re-convened three business days later at the same time and place. The directors present at a Board meeting each hold one vote and resolutions are approved by a simple majority. A director can be represented by an appointed alternate director if they cannot attend the meeting themselves, provided that the director has notified the Board in writing that an alternate director has been appointed to take their place. Any director can call a Board meeting or propose a resolution for the agenda, but the dates and agendas are usually set by the Chairman. The Company Secretary is responsible for the programming and administration of meetings and for preparing draft Board minutes as soon as practicable following the meeting, which are then finalised by the Chairman and submitted to the Board for approval. The NNB GenCo (SZC) Vice Chairman provides support to the NNB GenCo (SZC) Chairman, reviewing the agenda for each meeting and the draft minutes prior to finalisation by the Chairman, and acting as chair of NNB GenCo (SZC) Board meetings in the absence of the Chairman.

4.7 Delegated Authority The NNB GenCo (SZC) Board has delegated authority for the operational management of the business to the MD and the Executive team. The delegation is based upon the following key principles:  Delegation of authority will be consistent with Nuclear Site Licence conditions, Environmental Regulation, the Shareholders’ Agreement and any other applicable agreements, regulations, and legislation.  Authority is delegated to individual roles within NNB GenCo (SZC) not to committees. The delegation framework is focused on empowering individuals by clearly defining who can approve key business

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decisions. Authority thresholds are based on identified business need and are not a reflection of seniority within the organisation.  Authority levels cascade through the business to enable the Executive Team and their reports to make effective ‘business as usual’ decisions.  NNB GenCo (SZC) Board Committees are consultative bodies with no voting rights and have, in themselves, no decision-making authority.  Certain matters may need to be approved above the NNB GenCo (SZC) Board (the “Reserved Matters” under the Shareholders’ Agreement), and these will be referred to the NNB HoldCo (SZC) Board for decision.

4.8 Sub-Committees The culture of NNB GenCo (SZC) embodies robust and effective challenge to its safety policies, standards and performance. To discharge its responsibilities, it has established and interacts with several executive advisory and challenge committees. The NNB GenCo (SZC) Board ensures it is properly briefed by these committees to ensure decisions are made with full knowledge of the facts and issues. The NNB GenCo (SZC) Board and supporting committees are outlined in Figure 6, and details of individual committees are listed in Appendix 1.

Figure 6. Sub-Committees

5 ORGANISATIONAL CAPABILITY

5.1 Staffing SZC is taking forward lessons learned from how the HPC Project has set up its client/delivery activities. A key driver for SZC is to replicate HPC as much as possible, to leverage skills, experience, and capability, alongside learning. Taking the HPC learning on board has identified opportunities to enhance and improve the delivery model for SZC to

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improve control of the schedule, costs, quality, and nuclear safety, and is aided by the Organisational Development Committee. (See Fig 6 above) The client resourcing approach for SZC is like HPC, i.e. a mix of employees, embedded contractors, and expats. The SZC project has its own headcount and staffing budget allocated as part of the annual planning process. However, recognising that HPC has skills and expertise to support SZC, an inter project service agreement (IPSA) has been put in place for HPC to carry out work on behalf of SZC. There are some key differences for SZC,  The project is a replica in design, then numbers of staff in some areas are much reduced, in particular those in engineering design, in Design Authority, and in other areas that have had a key role in development of the base design, such as independent nuclear assurance, and the management of the responsible designer contracts.  The organisation will have a core capability, but there will be no procurement occurring prior to FID, so a large Project Delivery Organisation organisation is not required prior to FID. A key focus of resource planning is on the socio-economic opportunities presented by the new nuclear projects. Early construction workforce mobilisation activities for SZC have considered these opportunities, for example a conveyor belt model to transition skills from HPC across to SZC, also opportunities to link colleges of further education from the regions. Long term planning is carried out using a methodology to identify skills required against major milestones. This is mapped to the EDF Energy job family architecture (JFA), which supports integrated resource planning across HPC, SZC and NG. This is a best practice approach adopted in many organisations. The JFA can be rolled up to provide a view of skills within key buckets, e.g. Engineering, Commercial, Quality/Assurance. This allows analysis to be completed to understand the trend of the future workforce, which supports long term resource pipeline activities, such as determining graduate discipline and volume requirements. The requirement for SZC delivery organisation will be largely like the demand for HPC, This will form the basis for discussions with project teams to identify short and mid-term resource requirements. It also enables long term strategic planning of skills development pipelines, such as science and engineering graduates. Therefore, this forward view, alongside HPC actuals, can be used to support early planning activities, such as development of the nuclear baseline.

5.2 Nuclear Baseline The Nuclear Baseline (NB) is an integral part of the arrangements that demonstrate that NNB GenCo (SZC) 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 and is managed through the company’s resource strategy [Ref 12].

NNB GenCo (SZC) recognises the importance of the NB throughout the lifecycle of the project and has developed an approach that draws on best practice and reflects regulatory and industry guidance.

The NB has several purposes:

 To demonstrate that NNB GenCo (SZC), 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.

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 To describe responsibilities to adequately manage the design supply chain and ensure adequate technical competences to oversee the nuclear, environmental, and other 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 and environmental 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 (SZC) is in control of activities through the right allocation of responsibilities for all work that has the potential to impact on nuclear, environmental, and industrial 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. The NB will be updated at appropriate intervals to take account of changes to the organisation. The NB provides the detailed roles, capability, and posts to support NNB GenCo (SZC) as an NSL and Environmental permit holder in addition it also identifies vulnerabilities and the associated mitigation. To achieve the NB as described above, the overall resource requirements and manpower needs within NNB GenCo (SZC) are managed through the Resourcing Strategy [Ref 12] and the supporting budgets and Medium Term (2 year) Plan. Maintaining a capable licensee organisation with be achieved through:

 Recruitment of staff commensurate with the Resourcing Strategy [Ref 12].  Competency Assessment and Training.  Succession Planning, and  Managing Change. NNB GenCo (SZC) have developed processes and an organisation to support the safe procurement of materials and services relating to the build of SZC. They demonstrate how NNB GenCo (SZC):  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).  Identify and control interfaces with Responsible Designer procurement processes via Interface Specifications.  Identify appropriate interfaces with supporting organisations and departments such as Design Authority and Construction via the Inter-Project Services Agreement (IPSA), and  Control procurement.

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5.3 Control of Organisational Change NNB GenCo (SZC) recognises the importance of identifying and managing organisational change and has produced and is currently implementing robust arrangements which apply throughout the organisation and will have an appropriate organisation in place to support it under the HR Director. These arrangements include:

 Identification of what constitutes an organisational change.  Description and categorisation of organisational change based on the potential impact on the NNB GenCo (SZC) NB (impact on roles/posts/IC status).  Assessment, planning and success criteria of the organisational change.  Consideration and Approval of the change through the Nuclear Site Licence arrangements (Licence Condition 36).  Post implementation assessment of the change and close out. The arrangements once implemented will consider the cumulative effect of changes on the organisation and identify any mitigation necessary. Applying organisational change in this way will ensure changes are fully assessed to ensure NNB GenCo (SZC) remains a competent licensee, justified and the NB is appropriately maintained by keeping a record of organisational changes.

5.4 UK EPR intellectual property The intellectual property for UK EPR is owned by EDF SA. HPC has a perpetual right to use, royalty free, the intellectual property for UK EPR for all HPC purposes, but not to build a further EPR. HPC is a single purpose company, as required by the HPC contract for difference.

The intellectual property provided by HPC’s contractors is either licensed to or owned by HPC, depending on whether the intellectual property is background or foreground intellectual property and depending on the contractor. HPC’s rights of use in such intellectual property range from a full right of use for all purposes for any project to a right of use limited to HPC’s purposes.

SZC will have, at a minimum, similar intellectual property rights as HPC for all SZC purposes, specifically to enable it to construct and operate a copy of HPC as built and modified. The terms on which SZC acquires those rights are not yet settled with EDF SA, HPC and relevant suppliers (or with HMG).

SZC is taking a two-staged approach to securing the intellectual property rights which it requires for development of the SZC project:  Rights already in existence: SZC Co already has certain arrangements in place with HPC and HPC’s suppliers for the sharing and licensing of intellectual property to SZC Co. SZC Co has been undertaking progressive work to fully map the scope of rights already granted to it.  Procurement of additional rights: Where SZC does not have in place pre-existing rights, SZC intends to enter standalone contracts with relevant EDF entities and relevant suppliers of HPC. These agreements will be in place prior to or at FID and will apply retrospectively.

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5.5 Transfer of know-how and lessons learned In addition to securing appropriate and adequate intellectual property rights, NNB GenCo (SZC) has established arrangements to ensure that the knowledge originating from and being developed through HPC and SZC’s shared capability is captured. In addition, NNB GenCo (SZC) will be a member of the EPR Owners and Operators Group (EPROOG) at FID and will, in advance of commercial operation, join and establish links with the World Association of Nuclear Operators, (WANO).

In line with feedback from the ONR that it found the HPC project execution plan useful, SZC and HPC are currently developing a project execution plan for the SZC project (the Project Execution Plan). The intention is that the Project Execution Plan will be an all-encompassing internal resource, setting out both key information about the SZC project (for on-boarding purposes) and SZC’s proposal for delivery of the SZC project, using lessons learned from HPC. HPC is actively contributing to and working with SZC to develop this Project Execution Plan, which will set out the consensus reached between SZC and HPC on optimal project delivery.

5.6 Supply Chain Strategy SZC Co’s replication strategy is predicated on the reduction in risk that can be delivered through SZC being developed as the 7th and 8th EPRs worldwide (and the 3rd and 4th versions of such units in the United Kingdom). This replication strategy and reduction in risk in turn allows SZC Co to deliver a project which presents values for money for both the consumer and HMG.

By adopting a replication approach, using suppliers that have provided qualified equipment for HPC, NNB GenCo SZC will be able to contract with a known entity that has already worked on HPC, leading to a reduced risk of delivery due to experience gained on the lead project, HPC.

In practice this means that NNB GenCo (SZC) will contract with the same contractors (or affiliates of those contractors) for key supply chain contracts which are essential to secure the EPR design. It will also contract with contractors who are required to support the wider implementation of the replication strategy (for example where it would take too long to re-qualify equipment from a different supplier, where the use of different equipment could have a ripple effect on design or where the contractor has key and valuable know-how from its work on HPC. In assessing whether to replicate a contract from HPC, NNB GenCo (SZC) is taking into account the contractor’s performance on HPC, and will need to adapt if, for example, a contractor withdraws from the market or withdraws its product from the market.

NNB GenCo (SZC) is also aiming to obtain a sequential transfer of key personnel from working at HPC to working on SZC. Use of the same construction and erection contractors ensures replication of the build and sequence methodology, reducing construction risk and optimising productivity.

6 SAFETY GOVERNANCE

NNB GenCo (SZC) has developed an overarching Nuclear, Health and Safety, Environment and Quality Policies (Ref. 8,9,10,11). The underpinning management arrangements reflect best practices, processes and procedures as reflected in IAEA requirements, WANO advice, ISO standards (e.g. ISO 9001, 14001, 45001) and guidance from the EA and the ONR in addition to its current parent company EDF SA, the world’s largest owner and operator of nuclear

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power plants. SZC will also be members of the EPROOG which will allow the sharing of operational experience of the worldwide EPR fleet.

The NNB GenCo (SZC) Board has responsibility for Safety and is ultimately accountable for all Safety related decisions and will ensure that excellence in safety is at the forefront of what we do throughout the organisation. This will be achieved through:  Establishing and implementing effective safety, health and environmental protection policies based on national and international best practice and guidance, as well as legislative compliance.  Establishing and maintaining a risk assessment and work authorisation process to manage industrial hazards.  Establishing reasonably achievable.  Overseeing that sufficient competent persons and other resources are provided to execute all nuclear licensed, permitted, and consented activity.  Overseeing the NNB GenCo (SZC)’s Safety performance, including receiving and reviewing reports and implementing recommendations from the Safety, Health and Environmental Committee.  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.  Overseeing the implementation of adequate arrangements to control any change to NNB GenCo (SZC)’s organisational structure or resources which may affect Safety.  Ensuring Safety takes priority over commercial performance objectives; and  Reviewing the effectiveness of NNB GenCo (SZC)’s security and emergency arrangements.  Overseeing an effective safety, health, and environmental protection culture, specifically implementing a strong nuclear safety culture within the project enabling a proactive identification and mitigation of Safety hazards and ensuring that environmental impacts are as low as The NNB GenCo (SZC) Board is assisted by the Safety, Health and Environmental Committee (SHEC) and the Nuclear Safety Committee (NSC) as per their definitions in Appendix 1. The Safety, Licencing and Assurance director will have specific responsibilities within the organisation for safety related issues, as below. Industrial Safety The Industrial Safety function, within the safety directorate, provides leadership for the development and effective implementation of policy and standards, and ensuring that arrangements and performance of the project organisation and the supply chain are compliant with the requirements of the Health and Safety at Work Act and associated legal requirements. The team will ensure that the requirements of the Construction Design and Management (CDM) Regulations throughout the design, construction, and commissioning phases of SZC Project are fully addressed. The Industrial Safety Team will support the development of industrial safety strategy and policy as ‘Client’ under the CDM regulations. Independent Nuclear Assurance The Safety Licencing and Assurance Director will have in place an Independent Nuclear Assurance (INA) function to maintain oversight of NNB GenCo (SZC)’s activities and will report on Safety and overall organisational performance to the Board and its supporting committees as appropriate.

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Within the INA organisation there will be the following functions:  Independent Technical Assessment, (ITA) - Providing independent review and assessment of the SZC safety case, Category 1 and 2 modifications, and a sample of design deliverables. ITA will manage the Nuclear Safety Committee (NSC) process and provide independent advice at NSC meetings. ITA also leads or supports the Concurrence process for Primary and Secondary Hold Points.

 Independent Assurance and Challenge Organisation (IACO). Providing independent assurance of the SZC project team and its suppliers, using audits and reviews, and reporting findings directly to the concerned functions, Suppliers and to the SZC Senior Management Team as appropriate.

 Independent Site Inspection- This team will provide independent review, oversight, and challenge of the sites Nuclear, Environmental and Industrial Safety, during the construction phase, and will provide feedback findings directly to the relevant functions and to management. This to ensure the robustness of the organisation, control of risks and its compliance with Regulations, International Standards, and internal policies.

 Regulatory and Licencing- This team manages the process interface with our regulators, identifying key issues and ensuring their effective and timely management and resolution within a framework of proportionate regulation. They also optimise regulatory engagement and working arrangements to realise the benefits of proportionality and manage the Hold Point Process to ensure smooth and timely governance of key project milestones. Security The Security team, within the Safety directorate, assesses all threats to the Project and specify security controls to be implemented by operational teams and Industry Partners to reduce the overall exposure of Project activities to the effects of malicious acts. The project key security objectives are to: • Identify key assets requiring protection and the risk of harm to those assets through objective threat assessment and risk management activities. • Specify and communicate physical, personnel and information security controls which adequately mitigate threats to business operations. • Assure delivery of agreed security standards, provide specialist advice and measure success or non- compliance. • Continually seek to improve through organisational learning, self and independent assessment, analysis and reporting of useful metrics and the pursuit of innovation. Design Authority The Engineering and Delivery organisation will include a robust Design Authority (DA), The Design Authority is responsible for design acceptance and assurance, ensuring that the SZC design meets UK requirements, this includes production and maintenance of the safety case, providing focussed expertise for the resolution of design issues; providing the overall design authority technical capability for SZC. As part of this, the high-level responsibilities of the DA Function are:  The ownership and production of the safety case.  The process for the acceptance of safety significant design and safety case changes.  The oversight and acceptance of the safety analysis that underpins the design and its safety case.  The oversight and acceptance of the safety justification that underpins the plant integrity.

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As SZC is a follow on “second of a kind” project, the DA Function is smaller than that of its precursor plant, HPC, – in size and scope of work. This is because of much of the design being completed by the HPC project, and the main role in the design area is to ensure replication is achieved safely. The DA retains responsibility for the SZC safety case. The DA Function acts as the Intelligent Customer (IC) / DA capability for the safety case and safety analysis. In the current phase of the project, the Design Authority (under the HPC Project Director) has responsibility for the Independent Technical Assessment (ITA) of safety related documentation, under an Inter-Project Services Agreement (IPSA). SZC will have its own DA established within the TSO (See Appendix A.2.4) prior to FID and award of the Nuclear Site Licence and Environmental permits.

7 ENVIRONMENTAL PERMITS

7.1 Overview Activities in the project phases of construction, commissioning, and operation of SZC will require environmental permits to be granted by the EA under the Environmental Permitting (England and Wales) Regulations 2016. Some permits will be relatively limited in scope and will only affect activities undertaken in the construction phase. Three permits supporting the commissioning and operation of the power station, referred to as ‘operational permits’, are being applied for early in the project lifecycle so that they can be considered in parallel with the application to the IPC for a Development Consent Order. The environmental permits do not just contain numerical limits that must not be exceeded - the fundamental permit conditions relate to the requirement for a permit holder to have suitable management arrangements, including an organisational structure and governance and sufficient competent persons and resources to operate the activities covered by the permit. The permits also require the use of ‘best available techniques’ (BAT) to minimise impacts on the environment. An environmental permit is required for the operation of large combustion plant - a ‘combustion activity’ - such as the essential diesel generators and any associated plant which is required to provide power in the event of a loss of grid supply. The permit requires the operator to use energy efficiently, to avoid, recover and dispose of waste produced by the activities, to establish and maintain controls to minimise the risk of pollution and any emissions from the installation, to monitor emissions and to maintain and implement an Accident Management Plan. NNB GenCo (SZC) is planning to make an application for a combustion activity permit. The discharge of cooling water, trade effluent and treated sewage effluent to coastal waters requires a permit for a ‘water discharge activity’. The permit conditions and limits are designed to ensure the operator uses BAT to minimise impacts on the marine environment from temperature, impingement of fish and marine organisms and chemicals in cooling water discharges. NNB GenCo (SZC) is planning to make an application for a water discharge activity permit. Schedule 23 of the regulations is referred to as the Radioactive Substances Regulations (RSR). Under the RSR, the EA is responsible for regulating all disposals of radioactive waste from nuclear sites in England; “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 (SZC) is consistent with that required by the EA for determining an application for an environmental permit. It is in line with the UK strategy for radioactive discharges 2009 [Ref.16] and proposes limits on radioactive discharges from the site that will deliver good environmental protection. The EA will invite comments on environmental permit applications made by an operator after determining that the application is duly made. The applications will be placed on the public register and comments sought. The EA has a policy of increased consultation on applications at sites where they consider there is, or is likely to be a high degree

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of public interest. In these situations, they may engage in additional consultation activities including consultation on the draft permit and their decision document. The approach is tailored to specific local circumstances. For all the environmental permits, arrangements for compliance are already or will be integrated within the NNB GenCo (SZC) 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. Environmental Safety The Environment team, within the Safety Directorate, are responsible for setting Policy and Standards in the areas of: Environment, Sustainability, Decommissioning, Emergency Preparedness and Business Continuity, the Environment team are also responsible for Environmental design, review, and acceptance. The team is also responsible for securing the required environmental permits to support the project execution and operational arrangements. The key areas of responsibility are. • Strategic interface with the Environment Agency • Environmental Permits and Consents • Site Support and Assurance • Managing Environmental Arrangements • Supply Chain and Delivery Management Support • Design and Modification Process Support • Decommissioning Support • Sustainability Support • Business Continuity and Emergency Preparedness- post FID

8 PROJECT PHASING

NNB GenCo (SZC)’s approach to the SZC project is to utilise best practice and to take advantage of operational experience from the sister plant at HPC and the guidance of organisations such as the IAEA, WANO, and INPO in developing NNB GenCo (SZC) standards. As discussed below, NNB GenCo (SZC) is also taking advantage of the best practices of EDF Energy Nuclear Generation and its parent Company EDF SA, who are experienced designers, constructors, and operators of nuclear power plants. Appropriate arrangements will be produced, implemented, and demonstrated in advance of each phase of the project. This phased approach will allow sufficient time for NNB GenCo (SZC) to identify lessons learned and make improvements, and for the Office for Nuclear Regulation (ONR) and the Environment Agency (EA) inspection of the arrangements to assure effective implementation. The basic phases of the project are outlined below:

 FID and DCO. Final Investment Decision hold point provides the financial support and confidence for the project. The Development Consent Order provides infrastructure planning agreement to proceed. For SZC the DCO provides security and confidence for investors to achieve FID.  Pre-Construction - NNB GenCo (SZC) is currently in this phase of the project. During this phase, NNB GenCo (SZC) are controlling detailed design, procurement and manufacturing of long-lead time items, and

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preparation of the site, including early and preliminary works for construction. NNB GenCo (SZC) 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 nuclear 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 (SZC) 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 (SZC)’s lifting of its Hold Point for Operation (described below). It includes maintenance, examination, testing, operation of the plant, and the treatment, processing, keeping, storing, accumulation or carriage of any radioactive waste, and  Decommissioning - This phase consists of dismantling, decommissioning, and removal of the plant following completion of operation. The phases are not necessarily distinct and are likely to overlap. For example, 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 reactor and turbine units will be staggered, such that the first unit is expected to become operational while the second unit is still undergoing construction and commissioning. The overall programme for the construction at SZC, incorporates:

Enabling Works:  The site preparation works.  Construction of a cut off wall to control groundwater.  Earthworks.  Construction of the local to site accommodation campus.  Construction of the beach landing facility.  Works in the local area to facilitate vehicular movements etc. Nuclear Safety Related Works  Construction of SZC, including the nuclear island, the balance of plant, ancillary buildings and structures.  Construction of the Interim Fuel Store.  Construction of the cooling water infrastructure.  Commissioning.

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Restoration works  Dismantling and removal of the beach landing facility superstructure,  Removal of the on-site accommodation campus; and  Landscaping.

8.1 Sizewell C Hold Points The project will 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 (SZC) recognise that HSE or EA may select any of the identified hold points for formal regulatory hold points or impose additional ones within their powers. The NNB GenCo (SZC) process for defining, managing, and releasing these hold points is described in Ref 13, including the management of ONR & EA permissions.

NNB GenCo (SZC) have defined a set of primary hold points outlined below:

 Replication.  Final Investment Decision  First Safety Concrete; (~ 2 years post FID)  Nuclear Island Concrete.  Non-Active Commissioning.  Active Commissioning.  First Criticality; and  Rating Certificate.

It should be noted that the Hold Point List will develop and change as the project progresses. Each of the specific hold points will have a set of specified assessment criteria to determine whether permission should be granted by NNB GenCo (SZC) to release the hold point and proceed with the work. These criteria are determined by the nature of the operation to be performed and the risks associated with it. They may be related to the organisation, procedures, competency & training, safety case documentation, availability of systems, or to the maturity of key elements of the design.

In addition to these proposed primary NNB GenCo (SZC) hold points, NNB GenCo (SZC) will have set secondary and tertiary hold points to ensure that work does not proceed until specified pre-requisites and approvals have been satisfied.

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9 SZC SITE ORGANISATION (AROUND FID)

The Engineering and Delivery Director will have full responsibility for the SZC Site and activities during construction and up until handover to the Pre-Operations Director. The key responsibilities of the Engineering and Delivery 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 SZC site, and  Establishing and maintaining a site organisation to deliver the project and satisfy nuclear site licensing and environmental permitting requirements.

The detailed construction organisation is currently being developed based on operational experience from the HPC project and reviews of industry best practice. This will be covered in a revised NB prior to first nuclear safety concrete. The functions that will report through to the Engineering and Delivery Director will include:  Off-site Construction.  Nuclear, Environmental and Site Controls.  Construction Support.  Site Engineering.  Commissioning.  Construction Safety; (Industrial safety inspection and advice.)  HR, Business and Site Support.  Security.  Construction Training; and  Organisational Learning. Key interfaces between the SZC site and central NNB GenCo (SZC) 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. During the construction phase, the intent is that the design will be received by the Construction Support Team as accepted by the NNB GenCo (SZC) DA. The design packages will be supplied to the SZC Construction Team for the build.

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It should be noted that prior to SZC first nuclear safety concrete commencing, the impact on the SZC Organisation (and its support from EDF, and EDF SA as the RD) will be assessed to ensure appropriate resources are available.

Figure 7; Integrated Management System Schematic

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A.1 Sub-Committees

A.1.1 Sizewell C (SZC) Project Board The SZC Project Board oversees the engineering, consents & licensing, procurement, construction and commissioning of the new nuclear plants at Sizewell C to enable them to be delivered safely, to quality, on time, to budget and to enable the plants to operate at their design intent. The SZC Project Board acts as the accountability forum for project performance against targets including those set by the NNB GenCo (SZC) Board and for sharing of key information to enable effective coordination of project activities. The SZC Project Board has the role of performance oversight of the SZC project including:

 Review and discuss performance against safety (including nuclear safety), security and environmental standards, or planning commitments, and recommend actions to address any issues identified.  Review and discuss progress against Environment, Social and Governance (ESG) or sustainability principles, priority areas and requirements, and recommend actions to address any issues identified, as reported into the Board by: o The SZC Environmental Sustainability Committee (ESC). o The SZC Employment, Skills, Socio-Economic (ESS) Impact Committee.  Consider any identified quality issues / non-conformances and provide recommendations to address the same.  Monitor progress against the approved baseline schedule and consider methods to address any issues.  Monitor the actual cost of work performed against the approved budgets and propose actions to address any issues.  Consider design proposals and propose actions required to progress appropriately.  Review the commercial performance of supply chain contracts.  Consider any significant project level risks and recommend appropriate risk mitigation strategies and actions.  Review of team working / resourcing arrangements and consider actions to address any issues.  Monitor effectiveness of the stakeholder management arrangements and identify actions to address key issues.  Consider Engineering and Delivery challenges and propose actions to address any issues.  Develop functional strategies and management plans to ensure alignment with SZC values, systems and processes.  Consider whether Company policies are appropriately assessed and implemented.

A.1.2 Organisation & Development Committee The Organisation & Development Committee is a joint board with HPC and provides governance over the Organisational Development and People Strategy under the Human Resources Director. The Board provides governance by overseeing and monitoring performance of the Strategy so that HPC and SZC are both capable of

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meeting key Project milestones and on into operations. All people related committees report to this board e.g. NSC / Training committees.

 Providing governance for organisational development change control, both nuclear baseline and non- nuclear baseline.  Oversight of compliance with LC 36, Organisation Capability.  Approval of the long-term resourcing strategy for the HPC & SZC projects.  Oversight of client workforce skills capability, with interface to nuclear baseline competence management, acting as the senior leadership team for nuclear baseline related training; approving training programmes, overseeing development and reviewing effectiveness of training delivery.  Oversight of construction workforce intelligent client role implementation and measurement and interface with construction workforce mobilisation.  Oversight of employment & skills legacy and socio-economic measurement terms.  Monitoring of the development of the leadership capability across HPC & ND ensuring there are adequate processes in place to secure the overall strength of the organisation.  Oversight of the development and execution of the pipeline programmes, e.g. graduate/apprentice programmes.  Ensure resilient succession plans are in place and take account of gender ambitions.  Oversight of workforce welfare resilience including feedback mechanisms such as the Project Survey.  Oversight of people related risks,  Oversight of HR performance against KPIs

A.1.3 Nuclear Safety Committee (NSC) NNB GenCo (SZC) has a Nuclear Safety Committee (NSC), [Ref 15] which acts as an independent advisory body providing Nuclear Safety advice to the NSC Chairman, NNB GenCo (SZC) Board and Executive Team to ensure they are able to make informed decisions. This is achieved by a brief from every meeting being produced by the NSC Chairman and presented to the NNB GenCo (SZC) Board and the Executive Team. The Chairman of the NSC also has direct access to the NNB GenCo (SZC) Chairman on all Nuclear Safety issues. The NSC is a requirement of the Nuclear Site Licence and is required to be formed of at least seven members, including one or more members who are independent of the nuclear site licensee’s operations. The qualifications, current posts held and previous relevant experience of the members of the NSC taken as a whole shall be such as to enable it as a committee to consider any Nuclear Safety matter likely to be referred to it and to advise NNB GenCo (SZC) authoritatively and, so far as is practicable, independently. Matters typically considered by the NSC are:  Nuclear Site Licence condition arrangement.  Safety cases.  Major environmental permit applications affecting radiological arrangements.  Major design changes, other than those arising from the Generic Design Assessment process.

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 Organisational development including significant management of change proposals.  Management system development, and  WANO/IAEA peer reviews and learning from other industries.

A.1.4 Independent Advisory Committee The purpose of the Independent Advisory Committee (IAC) is to assist the NNB GenCo (SZC) Board by providing an independent review of major pre-FID procurement decisions in order to ensure that concluded contracts represent value for money for consumers and are ultimately on acceptable terms for HM Government, regulators and potential financial investors.

The IAC is a formal sub-committee of the NNB GenCo (SZC) Board and comprises of at least four (4) members, being at least two (2) independent members (“Independent Committee Members”) and at least two (2) members of the SZC project team (“Executive Committee Members”).

The IAC may invite observers from EDF SA, Ofgem and HM Government to attend meetings of the IAC on a regular basis. Other non-members may be invited by the IAC to attend all or part of any meeting as and when appropriate and necessary.

The IAC meets quarterly or at such other times as a simple majority of the members of the IAC determine to be necessary or appropriate to carry out its duties.

A.1.5 Environmental Sustainability Committee (ESC) The purpose of the Environmental Sustainability Committee is to:

 Monitor the implementation of environmental sustainability principles, strategies, policies, and plans, identify areas in need of improvement and determine necessary solutions and actions.  Continuously challenge the SZC project against relevant sustainability best practice, acting as an advisory group to the Project Board.  Report to the SZC Project Board on progress and on any issues preventing implementation and progress.  Collaborate and align with others, particularly with the SZC Employment, Skills, Socio-Economic (ESS) Impact Committee, to understand and present the full ESG picture.  Decide on environmental sustainability elements that can be communicated internally and externally.  Support the Project on the planning and financing cases and therefore meet HMG and investor needs.  Demonstrate application of lessons learnt from HPC and other large infrastructure projects to support value for money case, for transition to low carbon, to support development of supply chain contracts.  Align activities with MTP and IPSA arrangements.

A.1.6 Operational Development Committee (ODC) (Post-FID) The Operational Development Committee oversees the development of the future SZC Station Operations operating model (strategies, processes and procedures) as well as the implementation of staff recruitment and training programmes to ensure that a best practice capability is in place to support the commissioning and operation of SZC

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in line with the project schedule. This will be constituted post-FID. The ODC’s key role is the oversight of development of the future operations capability including:  Overseeing the development of the future operating model for the stations; approving strategies, high-level processes and monitoring the development of procedures in line with the required operational development schedule.  Overseeing the implementation of the resourcing strategy for operations, approving recruitment strategies, and monitoring the progress of recruitment.  Act as the senior leadership team for operations related training, approving training programmes, overseeing development, and reviewing effectiveness of training delivery.  Overseeing the development of information systems and management information capabilities for the operational environment.  Monitoring progress against the operations schedule, initiating actions to address any issues, and agreeing any significant schedule changes within delegated authority of Pre-Operations Director.  Overseeing the delivery of the SZC simulator and management of operational facilities on the SZC site.  Overseeing design issues and licence or permit compliance affecting future operations.  Monitoring the operational development risk log as well as risks in the project risk logs that are relevant to future operations.

A.1.7 Safety, Health and Environment Committee (SHEC) (Post-FID) The SHEC will be chaired by a NNB GenCo (SZC) Director and the Safety and Assurance Director (post FID) and meet at least quarterly. The members of SHEC will bring experience and expertise in Safety and environmental issues relevant to nuclear construction and operation. The SHEC is an internal implementation and monitoring committee and has the following principal responsibilities:  Advising the NNB GenCo (SZC) Board, making recommendations on policy development, arrangements performance and risks in relation to Safety.  Monitoring Safety performance, having regard to underlying trends and reviewing progress on improving Safety performance and Safety culture.  Monitoring occupational health performance, having regard to underlying trends and reviewing progress on improving the occupational health of staff, contractors, visitors, and the public.  Monitoring environmental performance, having regard to underlying trends and reviewing progress on improving the environmental impact of NNB GenCo (SZC) on society and its employees.  Providing advice on any significant changes to non-radiological environmental permits or processes.  Reviewing Safety risk exposures in NNB GenCo (SZC)’s risk registers and ensuring the priority risks are accurately recorded.  Monitoring the Safety risks associated with NNB GenCo (SZC)’s operations and recommending risk mitigation actions as appropriate, and  Reviewing the impact of change to NNB GenCo (SZC)’s organisational structure of resources with respect to its impact on Safety.

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A.2 Design and Licensee Roles.

A.2.1 Intelligent Customer (IC) Capability NNB GenCo (SZC) will be the nuclear site licensee and environmental permit holder for SZC. It will be supported as appropriate by EDF SA including EDF SA’s nuclear engineering division (Division Ingénierie Projet Nouveau Nucléaire or ‘DIPNN’) and Edvance.

NNB GenCo (SZC) recognises the importance of being an IC for any services it procures or receives. This is particularly so given the key RD relationship with EDF SA, HPC and EDF. NNB GenCo (SZC) will have control of activities being undertaken on its behalf and be an IC for the services provided. Responsibility for IC rests with the Engineering and Delivery Director for NNB GenCo (SZC) The company approach to IC applied through the procurement procedures follows six basic steps:  “Make or Buy” decision.  Defining the nuclear or environmental safety significance of the work.  Specifying the work.  Assessing and selecting the contractor.  Oversight of work in progress; and  Accepting completed work. This will be applied throughout the business in areas such as:  Procurement and Contract Management.  Design review and acceptance.  Design Change.

The Engineering and Delivery Director acts as the interface with the RD organisation on all aspects of the design and construction including procurement, detailed design and modifications. The NNB GenCo (SZC) will embody its own Design Authority (DA), embedded in the TSO organisation (Appendix A.2.4) reporting to the SZC Engineering and Delivery director and 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 RD to NNB GenCo (SZC).

Safety and Environmental IC roles within the NNB GenCo (SZC) organisation are specifically identified within the NB. Role and training profiles will be implemented to an appropriate compliant level (prior to NSL granting) for those IC roles to ensure capability across the organisation and ensure it is appropriately applied.

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For environmental requirements, resource will be maintained within the SZC project as the Intelligent Customer role, and suitable arrangements will be made with supplier organisations for relevant technical support should it be needed. This could be via the Inter-Project Services Agreement (IPSA) or contracts with technically competent suppliers. Radioactive Waste Advisors (RWA) and radiation protection experts (RPE) will be appointed and identified on the Nuclear Baseline when appropriate to support the project and operational station.

A.2.2 Responsible Designer The role of the RD is to manage the production of the design, to assist in the early stages of the procurement process, development of the construction schedule and management of the interfaces. EDF SA will be appointed by NNB GenCo (SZC) as Responsible Designer (RD) for SZC with appropriate arrangements in place to ensure NNB GenCo (SZC) has overall control and is an intelligent customer for those areas.

The design is a direct replication, wherever possible, of the HPC design, the detailed review and acceptance of this design has been substantially completed. The RD will support NNB GenCo (SZC) in the detailed design of any features that are SZC specific due to its geology and location, in application of any modifications that occur as a result of organisational learning on the HPC project, in the project management, contract management, manufacturing and construction surveillance and in commissioning. The RD consists of specialist resource within the UK and EDF SA. The RD role will change following initial operation and become one of support to the SZC DA in operational needs for the plant. EDF SA will be appointed as the RD through an agreement which will be put in place prior to granting of the NSL and Environmental permits. The agreement will identify the scope of services offered by the RD, which will include: Engineering:  Safety Case support.  Environmental Permitting Support, including BAT.  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, particularly HPC.  Support to NNB GenCo (SZC) in the management of relevant contracts, including design contracts, up to formal transfer of such contracts to NNB GenCo (SZC), and  Delivery of engineering documentation. Procurement:  Where required by NNB GenCo (SZC), undertaking and managing the technical specifications for NNB GenCo (SZC) approval of the contract, follow-up of manufacturing / inspections.  Manufacturing/Inspection Quality Assurance (QA) support.  Construction.  Construction/commissioning support and backup.

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RD activities will be integrated in the overall schedule of the project. The RD will perform the project control of its own scope in an integrated manner with NNB GenCo (SZC). NNB GenCo (SZC) will define the services and control the delivery and schedule of those services from the RD. Interface specifications will be in place prior to the agreement that describes the requirements from both EDF SA and NNB GenCo (SZC) for particular aspects of the plant.

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 SZC lifecycle.

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 (SZC) Engineering (includes roads, networks and the operational services centre.)

A.2.3 HPC and EDF Support

SZC is intended to be an exact replica of HPC wherever this can be achieved, exceptions being those that are related to geography, geology or environment. Where practicable, HPC staff will support the SZC project via the Inter- Project Services Agreement to formally provide knowledgeable and experienced assistance to the SZC team. This will be carefully considered and by appropriate resourcing will not be allowed to impact on either HPC or SZC IC, or on the operational NG fleet and project priorities or maintenance of licensee capability.

A.2.4 Technical Client Organisation (TCO) The TCO represents an alliance of each Licensee’s DA who own the safety case, and the Technical Services Organisation (TSO) that provides the underpinning technical expertise. The Licensees (currently being HPC and EDF Energy Nuclear Generation Limited) all undertake to agree to a common approach to the following in conjunction with the TSO that sits as a wholly owned subsidiary of EDF:

 Working arrangements.  Long term resource planning.  Resourcing the development of capability to meet the plan.  Development of technical strategy.

It is this agreement to a common collaborative approach that defines the TCO. The TSO Managing Director will chair a TCO Steering Board with each Licensee represented and will be empowered to drive a common approach across entities.

This collaborative platform will allow Licensees to own their resource whilst getting the benefits of a larger more resilient entity by co-location and long term resource planning in order to effectively support the future nuclear business structure of multiple Licensees and shareholders, and to meet the challenges outlined above.

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NNB GenCo (SZC) is not currently involved in the TCO or using the TSO. It is anticipated that the TCO arrangements may need to evolve to best support SZC post-FID. However, the TCO concept would deliver a solution for technical support for SZC that:

 Delivers technical competency (nuclear, engineering and environmental) as part of the Nuclear Baseline to each of the Licensees through the TSO which aligns resources from HPC and NGL into combined teams.  With time, will orientate common working practices across the TSO and the DAs of each Licensee.  Continues to support the UK EPR fleet as the organisation that accepts the design on behalf of the Licensee and in doing so ensures that it is constructible, licensable and operable in particular for SZC, leveraging from the HPC experience under the replication strategy.  Provides confidence for appropriate potential long-term investors that there is adequate provision and clear benefit in the TSO supporting ongoing nuclear operations into the future.

 The TCO will support each Licensee’s organisational requirements and will be designed and operated to ensure the Licensee retains control of its DA and the Nuclear Baseline.  On site plant construction, commissioning and operations remain the responsibility of the asset owner and Licensee.  Ensure necessary capabilities available across all plant life cycle phases,  In the interests of minimizing capability duplication and cost, and for consistency of approach, seek to maximise support off-site (of the Licensee premises) and centralise where appropriate.  The asset owner/Licensee retains direct control of the off-site Intelligent Customer capability for their plant.  Through joint medium term and annual planning between the TSO and the Licensees (through the DAs), ensure the TSO has both the capability and capacity to deliver planned work. Where the plan changes and capacity is tight the TSO will utilise the supply chain through Technical Support Alliance. A prioritisation protocol will be utilised in extremis.

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 The asset owner/Licensee will have a direct line of sight to the costs of technical support for their plant.  The TSO support capability will ultimately include in-house all the critical capabilities (other than DA) required to support the plants. Supply chain arrangements will be focussed on flexibility for capacity levels.  Common support functions required to enable the TSO capability to support the plant are included in the agreed plans and budgets (e.g. Enterprise Asset Management system).  The TSO will be co-located with the Licensee DAs in order to best support the DAs (and wider Licensee resources) in regulatory interface duties; leading to consistencies in standards and approach.  Neither the TSO or the wider TCO will have the identity of a nuclear site Licensee (as prescribed under Nuclear Installations Act 1965), and therefore will not have its own Nuclear Baseline. Posts in the TSO however will be attributed with roles which are included within one or more of the Nuclear Baselines of its client Licensees and so the TSO will maintain the technical capability of staff to perform an intelligent customer role. The DAs are directly on the Licensees baseline as in the current organisational structure.  To develop long term capability and to derive maximum benefit from the TSO, client Licensees will have common working arrangements and to joint resource planning. A joint TCO Steering Group will be established for governance in this regard, comprised of representatives from the TSO and the client Licensees and under the chairmanship of the Managing Director of the TSO.  A joint approach will be taken to the development of technical strategy. This underpins the principle of replication in the broadest sense bringing both safety and efficiency benefits. The Chair of TCO Steering Group will have the role to drive commonality and best practice, ensuring learning across Licensees, to develop an approach to technical issues that both meets commercial needs and manages risk to be ALARP. This technical strategy will be agreed by client Licensees and will provide the point of reference for the TSO delivery of technical services.

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NNB GENERATION COMPANY (SZC) LTD

COMPANY DOCUMENT NNB COMPANY DOCUMENT TEMPLATE PRE-CONSTRUCTION

Version 2.0 Date of Issue 30th June 2020 Document No. 100200200 Status Approved Next Review Date 31 st October 2020 Owner & Approver M P Lavelle Technical Reviewer R A Carr Author M Carnicero

© 2019 Published in the United Kingdom by NNB Generation Company (SZC) 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 GenCo, 90 Whitfield Street, London W1T 4EZ. The electronic copy is the current issue and printing renders this document uncontrolled.)

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APPROVAL SIGN-OFF:

Originated by: Date: 29/06/2020 Name: Marta Carnicero Title: Organisational Capability Specialist

Reviewed by: Date:29/06/2020 Name: Richard Carr Title: Head of OD & Change

Approved by: Date: 29/06/2020 Name: M P Lavelle Title: Safety, Licencing and Assurance Director

DOCUMENT CONTROL

Version Purpose Amendment By Date For Review Draft version to include Environmental Baseline roles 1.0 identified as Nuclear Baseline Roles for SZC pre- M Carnicero 22/04/2020

construction. Next version by 30th June 2020 Approved Version to support NSL application – SZC Nuclear 2.0 M Carnicero 29/06/2020 Baseline pre-Financial Investment Decision

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TABLE OF CONTENTS

1 SIZEWELL C NUCLEAR BASELINE INTRODUCTION ...... 4 1.1 Purpose ...... 5 1.2 Regulatory expectations for a Nuclear Baseline ...... 6 1.3 SZC’s Nuclear Baseline ethos ...... 7 1.4 Ownership of SZC’s Nuclear Baseline ...... 7 1.5 References and Definitions ...... 8

2 SZC’S NUCLEAR BASELINE APPROACH ...... 11 2.1 Defining the organisation and activities to which the Nuclear Baseline applies ...... 11 2.1.1 The ‘Nuclear Baseline activities’ ...... 11 2.1.1.1 SZC’s current activities to which this Nuclear Baseline Statement applies ...... 11 2.1.2 The Nuclear Baseline Organisation ...... 12 2.1.3 Posts and Roles which form SZC’s Nuclear Baseline Organisation ...... 13 2.2 Scope of SZC’s Nuclear Baseline ...... 14 2.2.1 Meaning of a Nuclear Baseline ...... 14 2.2.2 An integrated Nuclear Baseline ...... 14 2.2.3 SZC’s Nuclear Baseline Areas ...... 15 2.3 Overview of the Nuclear Baseline Methodology...... 16 2.3.1 SZC Nuclear Baseline arrangements ...... 16 2.3.2 SZC Nuclear Baseline data ...... 18 2.3.3 Iterations of SZC’s Nuclear Baseline ...... 18 2.3.4 The Nuclear Baseline and its relationship with other arrangements ...... 19 2.3.5 The Organisational Capability Database ...... 20 2.3.6 Nuclear Baseline Measures ...... 21

3 SZC ORGANISATIONAL OVERVIEW...... 22 3.1 Introduction ...... 22 3.2 Organisational Design Principles ...... 22 3.3 Summary of Organisation Design Changes Since the Last Issue ...... 23 3.4 Summary of Planned Organisation Design Changes ...... 23

4 RESOURCING & THE NUCLEAR BASELINE ...... 24 4.1 Resourcing Overview ...... 24 4.2 The Nuclear Baseline and Contractors ...... 26

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4.3 Role and Training Profiles ...... 26 4.4 Intelligent Customer ...... 27 4.5 Succession Planning ...... 28

5 CURRENT NUCLEAR BASELINE ...... 29 5.1 Nuclear Baseline definition ...... 29 5.2 Nuclear Baseline justification ...... 30 5.3 Nuclear Baseline status ...... 30 5.4 Nuclear Baseline Vulnerabilities Assessment ...... 32 5.4.1 Assessment Approach ...... 32 5.4.2 Summary of Vulnerability Assessment ...... 32 5.5 Actions for the Future ...... 41

6 RECORDS ...... 41

7 DOCUMENT REVIEW PERIOD ...... 42

APPENDIX A – THE NUCLEAR BASELINE PROFILE ...... 43

TABLE OF FIGURES Figure 1: The Nuclear Baseline within the Overall SZC Organisation Figure 2: Annual development of Organisational Capability Requirements Figure 3: Relationships between Posts and Roles Figure 4: Analysis of Nuclear Baseline Vulnerability Figure 5: Reference Baseline Figure 6: Vulnerability analysis – Comparison of Actual vs Reference Base Figure 7: Organisational Change Process Figure 8: Nuclear Baseline Growth 2020-2021

TABLE OF TABLES Table 1: Elements of the Nuclear Baseline Areas Table 2: Nuclear Baseline Measures - Current and Proposed Table 3: Nuclear Baseline requirements breakdown Table 4: Overall Nuclear Baseline Profile Table 5: Nuclear Baseline Summary

1 SIZEWELL C NUCLEAR BASELINE INTRODUCTION

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NNB GenCo Sizewell C (referred to as SZC unless otherwise stated) is applying for a Nuclear Site Licence (NSL) to undertake prescribed activities in accordance with the Nuclear Installations Act 1965, a licence to install and operate two EPR nuclear power reactors at Sizewell in Suffolk. An NSL application requires the submission of a Nuclear Baseline (NB) to support demonstration of SZC organisational structures, staffing and competencies. This document has been produced for the purposes of reporting SZC’s NB in support of its application to become a Licensee. This NB statement is supported by underpinning information and analysis which provides the organisational structure, roles and required numbers to provide oversight and the delivery of activities which impact upon: • Nuclear Safety including Radiation Protection and conventional safety; • Radiological Environmental Protection; • Security; and • Quality insofar as it supports the delivery of these. This NB Statement uses the term ‘Nuclear Baseline Areas’ as a collective reference to the four concepts above. This NB identifies Posts and roles for the pre Financial Investment Decision (FID) phase, with a look ahead to the next phases as far as they can currently be anticipated. The NB philosophy is to consider all activities, and therefore all roles including the broader responsibilities of direction and control, which could lead to an adverse impact on nuclear safety if they were not delivered to the right standard.

The next version of the NB will be produced by the end of October 2020 as the scope of a planned future delivery organisation is established. The NB will then be enhanced to support future milestones and phases post FID.

The NB Database will be updated on a regular basis and this NB document will be reviewed and updated as the project develops. Also, learning from HPC will be incorporated as part of the future versions and any changes will be communicated to the (Office for Nuclear Regulation) ONR during routine Level 4 interactions.

1.1 Purpose The NB is the means by which SZC demonstrates that its organisational structures, staffing and competencies are, and remain, suitable and sufficient to manage activities covered by the NB Areas, throughout the full range of SZC’s activities, for planned and reasonably foreseeable events including emergencies. It acts as the basis against which changes to the organisation can be managed and controlled. Note: The NB Areas covered by the NB are described more fully in Section 2.2.3. The SZC Organisation in its totality is designed to deliver the full range of its activities. These activities are not limited to the NB Areas and there are additional non-NB Area-focused organisational capabilities required to deliver the full scope of the SZC Project (referred to as the Project). As such, the NB relates to those parts of the SZC Organisation that are delivering those activities covered by the NB Areas. Therefore, the SZC NB Organisation is a subset of the total SZC Organisation; as illustrated in Figure 1.1 (see Section 2.1.2 for further detail).

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Sizewell C Organisation

Nuclear Baseline Organisation

Figure 1 The Nuclear Baseline within the Overall SZC Organisation

The NB (in relation to NB Areas): • provides a baseline definition of the organisation, including the management structure, required to deliver planned and reasonably foreseeable unplanned activities, against which changes can be managed and controlled; • supports demonstration, to both itself and the Office for Nuclear Regulation (ONR), that SZC would be a capable Licensee to hold a Nuclear Site Licence [Ref1]; • supports demonstration, to both itself and Environmental Agency, that SZC would be a capable Permit Holder to hold a Radioactive Substances Regulations Environmental Permit [Ref2]; • describes the Roles and responsibilities associated with each Post within SZC, for which individuals are required to be demonstrated as competent to deliver the SZC’s activities; and • identifies organisational vulnerabilities and enable them to be addressed.

1.2 Regulatory expectations for a Nuclear Baseline In accordance with Nuclear Site Licence Condition 36 [Ref3] and also those requirements associated with pertinent Environmental Permit conditions, including the standard conditions 1.1.1 and 1.1.2 of the Radioactive Substances Regulation Permit issued pursuant to Schedule 23 of the Environmental Permitting (England and Wales) Regulations 2016, SZC must have a ‘baseline’ organisation, which has the organisational structure, staffing and competencies to satisfy itself it is capable at any time in the project, including to install or to operate a nuclear power station. It is the ONR’s expectation that SZC, as a prospective Licensee, will provide an overall summary of SZC’s organisation and justification of the suitability of the persons allocated to deliver compliance with the NSL

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throughout all planned activities. This information is provided in the form of this NB Report, as part of the NSL Application dossier. Similarly, Environmental Agency (EA) expects that as a prospective Permit Holder, SZC will demonstrate that it has sufficient competent persons to comply with its Environmental Permits throughout all activities. EA encourages operators to include environmental capability needs within an integrated Nuclear and Environmental Baseline to address the requirement of the Radioactive Substances Regulations Environmental Permit. SZC considers the NB and Company Manual [Ref4] to be key elements of what could be considered as the organisational safety case for the SZC Organisation. The intended outcome of these two documents is a clear statement of the necessary capability and capacity that are required to ensure that accountabilities and responsibilities are adequate to ensure the safe, efficient and timely execution of activities by the NSL and Permit Holder. In addition, an Information Memorandum is under development to support the financial investment for SZC. SZC’s NB is developed using best practice and guidance, including guidance from the International Atomic Energy Agency [Ref5], Nuclear Industry Code of Practice [Ref6], ONR [Ref7], and Environmental Agency [Ref8]. SZC’s NB recognises and reflects the expectations of the ONR’s guidance and principles which has been produced for its inspectors when undertaking a technical assessment in support of making regulatory judgements and decisions.

1.3 SZC’s Nuclear Baseline ethos The NB requirements have been developed to be integrated with other related management arrangements. SZC is committed to ensuring that the definition and management of the NB is integrated into business as usual planning and delivery practices utilising existing arrangements and their outputs wherever possible. SZC’s NB data is maintained live and the defined NB document will be reviewed at key points throughout the phases of the project (next issue due in October 2020). This ensures the organisational NB requirements are fully considered, assessed and detailed (see Section 7 for further detail regarding the review of SZC’s NB) and that the organisation remains competent to deliver these requirements.

1.4 Ownership of SZC’s Nuclear Baseline The People & Organisational Development (OD) Director has ownership of and accountability for SZC NB on behalf of the NNB GenCo (SZC) Board of Directors (Board). The definition and maintenance of the NB is the responsibility of the Organisational Capability Specialist who acts on behalf of the People & OD Director, SZC Leadership Team and the Board. The Organisational Capability Specialist is part of the Organisational Development team that provides support to both HPC and SZC. The Head of People acts as an Intelligent Customer (IC) in specifying, reviewing & approving the SZC NB. The Organisational Capability Specialist ensures that practical delivery of the NB remains reflective of the organisational requirements covered by the NB Areas. Formal issue of NB publications (such as this document) follows a rigorous process, in line with SZC management arrangements, which ensures that all relevant individuals and bodies within SZC are involved in

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its review and assessment to consequently confirm that SZC is structured and resourced (in terms of both staffing and competency) sufficiently to conduct its activities safely. Competent persons led by the Organisational Capability Specialist on behalf of the People & OD Director undertake the process of developing and maintaining the NB. SZC leaders and line managers are also accountable for providing current and accurate information under the business arrangements.

1.5 References and Definitions

Ref Title Location Document No. Office for Nuclear Regulation http://www.onr.org.uk/licens 1 ONR Nuclear Site Licence Handbook website ing-nuclear-installations.pdf Gov.UK website https://www.gov.uk/governm Environmental Permitting Guidance ent/publications/radioactive- 2 Radioactive Substances Regulation substance-regulations-rsr- guidance Office for Nuclear Regulation https://humanfactors101.files. website wordpress.com/2016/06/onr- 3 Nuclear Site Licence Condition 36 licence-condition-36- organisational-capability1.pdf 4 Company Manual EDF 100200192

5 International Atomic Energy Agency IAEA website https://www.iaea.org/ Nuclear Industry Code of https://www.nuclearinst.com Practice /write/MediaUploads/SDF%2 Nuclear Baseline and the Management of 0documents/OCWG/Nuclear 6 Organisational Change (Issue 3 March 2017) _Baseline_and_Management _of_Organisational_Change_ GPG.pdf ONR website http://www.onr.org.uk/index.ht 7 Office for Nuclear Regulation m EA website https://www.gov.uk/topic/envir onmental- 8 Environmental Agency permits management/environmental- permits 9 Company Management System Manual EDF NNB-302-PRO-000015_SZC

10 Integrated Management System EDF TBC

11 Management of Change Procedure EDF NNB-302-PRO-000015_SZC ONR website http://www.onr.org.uk/saps/sa 12 Safety Assessment Principles (SAPs) ps2014.pdf 13 Company’s Resource Strategy EDF TBC EDF NNB-OSL-POL-000006 14 Intelligent Customer Policy Version 2.0

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Term / Abbreviation Definition DA Design Authority DCO Development Consent Order EA Environment Agency EDF SA Electricité de France Société Anonyme EPR The Pressurised Water Reactor developed and trademarked by Framatome (EPR™) FID Final Investment Decision FWP Forward Work Plan HPC Hinkley Point C HR Human Resource HSE Health and Safety Executive IAEA International Atomic Energy Agency IC Intelligent Customer IM Information Memorandum IMS Integrated Management System IPSA Inter-Project Services Agreement; the arrangement pursuant to which people resource is shared between HPC and SZC. IS Information System KPI Key Performance Indicator MD Managing Director MTP Medium term plan NB Nuclear Baseline NNB GenCo (SZC) NNB Generation Company (SZC) Limited, Company Number 9284825 NNB HoldCo (SZC) NNB Holding Company (SZC) Limited, Company Number 9284571 NOAK Next of a kind NSA Nuclear Skills Alliance NSL Nuclear Site License NG EDF Nuclear Generation Limited, Company Number 03076445 Barnett Way, Barnwood, Gloucester, GL4 3RS, OD Organizational Development ONR Office for Nuclear Regulation PCSR Pre-Construction Safety Report PEP Project Execution Plan QA Quality Assurance RAB Regulated Asset Base RD Responsible Designer RSR Radioactive Substances Regulation

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SHEQ Safety, Health, Environment and Quality SZC Sizewell C TCO Technical Client Organisation TSO Technical Services Organisation, operating out of EDF Energy (TSO) Limited WENRA Western European Nuclear Regulators Association

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2 SZC’S NUCLEAR BASELINE APPROACH

2.1 Defining the organisation and activities to which the Nuclear Baseline applies

2.1.1 The ‘Nuclear Baseline activities’ SZC activities are defined and agreed in a business plan which provides information on resource requirements and a programme for delivery of the Project. The Medium Term Plan (MTP) reviews work activities over a number of years and it considers the skills and resources required to complete this work before approving them.

The NB takes an activities-based approach to identify the Roles (see Section 2.1.3 for further details on Roles) that deliver activities covered by the NB Areas. Consequently, those activities on the business plan which fall within the scope of the NB Areas form the basis for deriving the ‘Nuclear Baseline Organisation’.

2.1.1.1 SZC’s current activities to which this Nuclear Baseline Statement applies This issue of the NB builds on the previous version (submitted in April) which only covered pre FID Environmental Baseline Posts with NB roles) and represents SZC at June 2020 focusing on the organisation pre FID.

SZC is currently in the first part of its Development Phase, which covers the period up to NSL Grant. SZC key activities during the Development Phase include:

• Site investigation and development; • Site preparation including preliminary works; • Safety and environment case production, including the SZC Pre- Construction Safety Report (SZC PCSR) and appropriate control of the design at this stage; • Processes for the procurement of long lead-time items; • Preparation for Construction (no work on site to commence during the Development Phase); • Preparation of the environmental permit applications; • Preparation of the NSL Application and Granting; and, • Preparation of the Project Execution Plan (PEP) and Information Memorandum (IM)

In addition, and to enable the above, there are a number of supporting activities which are equally important to the Project at this phase. These include: the development of the organisation, implementation of company processes and procedures including training, nuclear safety governance and financial control.

The Company Management System Manual (MSM) [Ref9] describes the processes to be implemented.

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The detailed objectives which underpin the delivery of the work areas will be provided in the Project Execution Plan (PEP) which is currently under development.

2.1.2 The Nuclear Baseline Organisation Details of the Company structure are given in the Company Manual and are not repeated here.

The organisational structure of SZC and the lines of authority have been put in place to ensure that SZC has a management structure with the capability and resources to discharge the obligations and liabilities connected with holding the NSL and Environmental Permits and to be fully in control of nuclear safety

The organisational structure is shown in detail in Appendix A 1.3 of the NB. The SZC Board will be made up of nine Directors. There are five Executive Directors and two Non-Executive Directors, one CGN Executive Director and one CGN Non-Executive Director. The Board structure is explain the Company Manual.

SZC resourcing requirements to deliver its activities are generated as a result of the business planning process and MTP. SZC is responsible for identifying the resources required to deliver the planned activities; this is captured in a resource plan.

The SZC Organisation is divided into functions. The Organisation Chart details the structure of the organisation in terms of reporting lines and Post titles within the functions. The SZC Organisation Chart records all Posts that are permanent SZC employees or embedded contractors (see Section 3.2 for further detail on embedded contractors). It also records for each Post, its status (e.g. occupied or vacant) and resource type (e.g. employee or embedded contractor resource).

SZC NB Organisation is a description of those Posts within the SZC Organisation that hold one of more NB Roles (see Section 2.2.1 for the definition of what makes a NB Role).

The NB Organisation is derived from, and is consistent with, the SZC Organisation Chart. The SZC Organisation Chart is reproduced for each function within Appendix A 1.3 of this document. All roles that could directly or indirectly affect nuclear safety (including environmental safety & security) will be classed as NB roles. All individuals that hold one or more NB role will be on the NB and be required to be competent in the allocated role. NB roles will be assigned to employees & embedded contractors. The NB will be verified to ensure clear lines of IC capability exist in the organisation to ensure that risk associated with contracted operations are controlled by the licensee organisation.

An illustration of the annual development of organisation capability requirements is below:

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Figure 2 – Annual development of Org Capability Requirements

2.1.3 Posts and Roles which form SZC’s Nuclear Baseline Organisation A SZC Organisational Post is made up of one or more Roles (see Figure 3); generally, these Roles will require a common skill set or purpose and therefore are aligned to create an Organisational Post.

Role Post Role Role

Figure 3 – Relationships between Posts and Roles

All roles that the Post holder is expected to deliver will have an associated Role & Training Profile (see section 4.3 for further details) which details the delivery expectations and required competency to enable successful and safe delivery of the role.

The significance of a role in terms of its potential to impact on nuclear safety determines whether it is in or out of the NB. SZC categorises all roles into three categories of roles:

• Appointed Suitably Qualified and Experienced Person (SQEP) / DAP (future operations role as part of LC12); • NB (including non-appointed SQEP); and • Business Competence.

Appointed SQEP and NB roles deliver activities covered by the NB Areas. Therefore, both form the basis of the NB; as such Appointed SQEPs are included as part of the analysis of NB roles. Appointed SQEP roles

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require appointment in writing in accordance with the Defining the Organisation Procedure, for example Radiation Protection Advisor or Duly Authorised Person, whereas NB roles do not.

A NB role is not just restricted to higher grades within the organisation. Consequently, Posts that carry out NB roles at lower levels within the organisation are also reflected within SZC NB Organisation.

NB Posts are those positions on the Organisational Chart that have one or more appointed SQEP or NB roles. Roles will therefore be categorised as either on the NB or not on the NB These are designated using the Reference NB (see section 2.3 for further detail on the NB Methodology for SZC).

2.2 Scope of SZC’s Nuclear Baseline

2.2.1 Meaning of a Nuclear Baseline The scope of activities to which the NB applies is captured by the NB Areas. These are judged on the basis that, where ‘action or inaction by an individual or group delivering activities covered by the NB Areas, which if inadequately conceived or executed could pose an immediate or latent (direct but not immediate) detriment’, these activities are within the scope of the NB. This is SZC’s definition as to which roles form part of the NB.

All Posts that contain an appointed SQEP and / or NB role are included on the NB.

The NB relates to the organisational capability required for the safe delivery of planned and reasonably foreseeable unplanned activities covered by the NB Areas (nominally for a defined stage of the SZC Project), including incidents and emergencies, not just the minimum required for safe operation or shutdown.

2.2.2 An integrated Nuclear Baseline SZC is committed to implementing and maintaining an Integrated Management System (IMS) [Ref10] that supports the streamlined delivery of its activities and includes addressing compliance requirements.

The NB embraces and reflects the integrated approach of the SZC IMS and the Power Station design by ensuring that all roles which are undertaking activities that could have a direct or indirect impact upon the NB Areas are defined, assessed and maintained. This recognises the interrelation of these activities and the impact one could have upon another; thus the NB adopts this integrated approach. As a result of the above, SZC has chosen that its NB has a wider remit than just nuclear safety, as is traditional.

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2.2.3 SZC’s Nuclear Baseline Areas The scope of the NB with regards to the activities it covers and the rationale for their inclusion within the NB is described within Table 1

Area Rationale for Inclusion Nuclear Safety (Including Activities concerned with the delivery and oversight of – and which have the Radiation Protection) potential to impact upon nuclear safety. Including ensuring protection against the harmful effects of ionising radiation. Security Activities concerned with the delivery and oversight of Security. This can be in terms of protection of SZC’s personnel and physical security and sensitive Nuclear information. Radiological Environmental Activities concerned with the delivery and oversight of ensuring Protection environmental protection from the effects of SZC’s radiological activities which could have a significant impact on the environment. Quality Activities concerned with the delivery oversight and assurance of quality of both SZC procured goods and services and SZC internal arrangements in so far as they support the delivery of Nuclear Safety Table 1 Elements of the Nuclear Baseline Areas

Note: Quality Roles are only identified insofar as they support the delivery of the other NB Areas.

A NB role may be attributed to one or more of the NB Areas. In order to understand all the impacts of a NB role, all of the NB Areas concerned with the delivery of that NB role will be recorded within the Role & Training Profile for each role, and subsequently the Organisational Capability Database (see Section 2.3.5). This allows identification of those roles that achieve compliance with a particular regulatory scope (e.g. only Posts delivering nuclear safety roles in accordance with the NSL requirements) within the integrated SZC NB. The Organisational Capability Database can be interrogated to provide a variety of data views and reports, such as those provided within the appendices of this document. SZC has developed the NB Database which will be transferred into a system for the future NB versions and it will create a SZC Track System.

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2.3 Overview of the Nuclear Baseline Methodology

2.3.1 SZC Nuclear Baseline arrangements The NB Procedure details how SZC defines, builds and maintains its capability to deliver its activities covered by the NB Areas through its NB and how subsequent changes to the organisation are controlled. These arrangements govern:  how SZC’s NB is developed;  how information is provided by the NB to aid decision-making; and  how and when updates to the NB are made.

SZC has developed a Reference NB that identifies the organisational capability requirements for the key project milestones which would allow better vulnerability analysis, when comparing to the NB, on vacancies, singleton SQEPs, span of control & IC. The Reference NB can also include non-nuclear baseline roles which would an assessment of the ability to do or deliver something rather than just to be safe and make the right decision. An illustration on how the revised process for analysis of NB vulnerability is shown below to support the Reference NB.

Figure 4: Analysis of Nuclear Baseline Vulnerability

Developing the Reference Nuclear Baseline The intent is to identify the organisational capability requirements for the key project milestones that identify the ‘Reference Baseline’ that the business needs in order to maintain Nuclear Safety, Quality and Compliance for each directorate. Performing this on an annual basis aligned to the MTP production allows vulnerability analysis to be automatically performed to assess the difference between competent people on the NB and the Reference Baseline.

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In developing the Reference Baseline each role will be assessed to determine:

 Upper band reference NB – model Organisation with sufficient resource and competence to discharge responsibilities for the delivery and oversight of nuclear safety against current IMS arrangements.  Lower band reference NB – showing the minimum resource / IC capability requirement should the project decides to contract out associated work covered by the IMS through third party organisations.

Figure 5 Reference Baseline

To ensure that appropriate upper and lower bands are identified the Reference Baseline will be owned by the respective programme director

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Performing Vulnerability Analysis Vulnerability Analysis will be performed for each role within each function and will compare the actual number of staff that are competent in a specific Role with the Reference Baseline.

Figure 6: Vulnerability analysis – Comparison of Actual vs Reference Base

2.3.2 SZC Nuclear Baseline data The breakdown of how the activities covered by the NB Areas are delivered across the organisation is described within the appendix as follows: Appendix A

 1.1 – NB Overall Profile  1.2 - NB Posts will be detailing which NB roles they hold in the NB database  1.3 - A pictorial representation of the organisational structure, highlighting the NB Posts within it.

2.3.3 Iterations of SZC’s Nuclear Baseline SZC NB details the organisational capability requirements for foreseeable NB related activities (determined by the Integrated Work Schedule), and most importantly is for the entirety of the stage that the Project is in. Therefore, it details all NB roles required to be in place at the end of a stage within the Project. SZC is committed to ensuring that as the project progresses it is and continues to be:  Properly constituted with a functional Board  Designed to match the needs of each phase of the SZC project and preparing for future phases

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 Structured, capable and functioning in a manner to ensure safety, environment and security related activities are being undertaken appropriately and planning for those activities anticipated in the future and;  An IC and operator with the right allocation of in-house responsibilities and capability.

The NB will be considered for updating:  Prior to a change in lifecycle phase;  As part of the ongoing Management of Change process  At annual review; and  Where the Organisational Development Board (OD Board) or other governance body consider that the NB requires review for any other reason

Governance is essential to ensure the Management of Change (MoC)process is robust and that organisational capability requirements and people risks are fully understood with mitigation being put in place were required. The OD Board will provide overall governance / oversight of the NB process and any organisational change.

A MoC procedure (Ref11) within NNB GenCo (HPC and SZC) has been developed to achieve proportionate control of any change to the organisation or structure which may affect nuclear safety. It sets out NNB GenCo (HPC and SZC) arrangement for compliance with NSL Condition 36 and the Environmental Permitting (England and Wales) Regulations 2010 (EPR) Condition RSR Permit Condition 4.3.5.

The procedure steps include:  Confirming the adequate arrangements for the human resources and financial requirements for proposed changes through committee review.  Confirming and ranking the nuclear safety impact of potential changes though initial assessment  Recording proposed changes  Producing a change proposal and categorising the impact and level of risk being considered,  Reviewing and approving proposals,  Implementing the change and  Undertaking a post implementation review.

2.3.4 The Nuclear Baseline and its relationship with other arrangements In order to ensure it is maintained (i.e. holds accurate information) and is able to act as an effective management tool, SZC NB has been integrated with other business arrangements and has been developed to draw upon and rely upon other business-as-usual arrangements wherever possible (see Figure 2.1 for further detail). This ensures a single source of information is used within SZC, and therefore helps avoid misalignment of the NB and business practice. The data that forms the basis of the NB will be captured within a management tool, the Organisational Capability Database, which will provide the current status of SZC NB along with other key data on organisational capability (see Section 2.3.5 below).

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2.3.5 The Organisational Capability Database The Organisational Capability Database is a tool used as the central repository for organisational capability data, including NB data, to capture, store and manage the information in a live manner. This database can be used to enable analysis both collectively (at an organisational level) and individually (at a post-or role-holder level). SZC has developed a NB Database and it will transfer the data to a system for future versions. Intelligent duplication from the HPC NB Database has been taken into account to create the NB database for SZC.

The overall philosophy for the management of the data within the Organisational Capability Database is to:

 Provide the organisation with a tool for the active management of the living NB  Enable Organisational Charts / lists to be produced automatically in order to capture the NB history within the IMS  Provide appropriate analysis and reporting tools to enable the monitoring of the status of the NB  Enable vulnerability analysis to be performed monthly in an automated, methodical manner to quickly identify and to address issues in the key performance indicators.  Support active decision-making and formal resource management for SZC.

The Organisational Capability Database is not maintained as a permanent record of the NB; however, it holds current underpinning data including all changes implemented in accordance with the MoC Procedure. This enables it to show accurately the up-to-date, approved NB Organisation and therefore provides the basis for the annual review of the formally issued NB. The figure 2.6 below illustrates the organisational change process:

Figure 7 Organisational Change Process

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2.3.6 Nuclear Baseline Measures The SZC NB database and the future Organisational Capability database will provide an ongoing means of monitoring the resource profile on a number of bases, for example post, role, individual, department and directorate. Within the Database is the data that can be interrogated to provide insight into the NB performance as it includes data on requirement, actual and any gap between the two. NB measures are intended to address:  Complement to deliver NB activities;  Competence to deliver NB activities;  Provision of a suitable and sufficient IC capability; and  The characteristics of the licensee organisation. The specific measures developed for SZC, given in Table 2 have taken into account industry guidance and identified areas that require management oversight at this stage in the organisation’s development. As the project progresses and the organisation matures, these measures may be added to with other factors identified in the guidance, such as demographics, overtime, health etc. At this point, the following measures have been chosen as useful indicators of performance. These will be reviewed as part of the Forward Work Plan (FWP).

Measures Metric % NB roles fulfilled COMPLEMENT Nuclear Baseline Where there is a gap between required resource and that in Roles resourced / place this will be reviewed as part of the ongoing management of the NB Database. This indicator looks at capability from a Vacancies role perspective. LICENSE ORGANSIATION % NB roles fulfilled by Employees / embedded Contractors Nuclear Baseline Roles resourced with Indication of the proportion of roles with NB roles not held by Employee/ SZC employees that are resourced Embedded Contractor % NB roles with competence needs gap COMPETENCE This will allow management action to be focused on areas Nuclear Baseline Role holders assessed as where there is a gap in competence and ensure adequate competent / mitigation is in place. This justification will be recorded in the with exceptions NB Database

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Measures Metric IC CAPABILITY Intelligent Customer Nuclear Baseline Role % IC NB roles with competence needs gap holders assessed as This indicator takes a view of how the organisation is delivering Competent / its IC function with exceptions

Table 2: Nuclear Baseline Measures - Current and Proposed

3 SZC ORGANISATIONAL OVERVIEW

3.1 Introduction The aim of this section of the NB is to provide sufficient detail of the nuclear safety roles and responsibilities within the organisation such that:  The allocation of roles which form the basis of the NB assessment are clear; and,  There is a basis against which future changes in organisation and responsibility can be assessed. This document consciously does not provide a description of the organisational roles and responsibilities as these are detailed within the Company Manual and MSM. However, a summary of the organisational design changes since the last NB statement and planned future organisation design changes are summarised along with the current Organisational Design Principles.

3.2 Organisational Design Principles Nuclear Organisation Design Principles have been developed to support development of both the Company Manual and NB. These have been developed using the Safety Assessment Principles (SAPs) [Ref 12], Technical Assessment Guides & additional guidance from the International Atomic Energy Agency (IAEA) and the Western European Nuclear Regulators Association (WENRA). The NODP are detailed within the reference document but can be summarised as follows:

 A robust organisation - The organisation, at all levels, shall be founded and maintained on an assessment of the structure, resource and competence needs for all activities which if inadequately conceived or executed could lead to a detriment on nuclear safety’  A nuclear capable organisation - The organisational structure and population of that structure shall support the achievement of nuclear safety aims and the overriding demonstration that SZC understands and is in control of nuclear safety in normal and emergency situations. The leadership

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and governance of nuclear safety and Intelligent Customer functions, including the management of interfaces with other organisations, are an intrinsic part of this demonstration  Strategic management of nuclear capability - There will be adequate in-house skills, resource and competence to manage nuclear safety and be an Intelligent Operator during normal operations and emergencies  Workforce Performance - Safety and quality are at the heart of what we do, within the context of careful cost management.  A capable workforce - Develop the core skills and capability required that will deliver SZC and support future activities.  Maintain Functional Capability - Operate in a matrixed way to maximise resources and learning and to support the delivery workflow to allow flexibility to meet changing demands.  Keep it simple and achievable - Minimise levels of management and ensure accountability sits at the right level.  Clear roles and lines of control & Responsibility - Everyone is clear on their level of accountability and decisions are made at the lowest possible level.  Continual Improvement - Continually improving efficient organisation supported by centralised services, such as recruitment delivery, IT support, facilities management.  Organisation Efficiency - Best use of available office space and technology, ensuring that teams are located where they will deliver with maximum effect with the right tools to achieve this.  Clear Communication - Everyone understands the shared schedule and how their role contributes to project goals and targets.  Diverse Workforce - Sustainable approach to diversity and inclusion, ensuring that D&I is embedded into project activities and planning for Operations.

3.3 Summary of Organisation Design Changes Since the Last Issue This section begins with is a brief summary of changes since the last issue of the NB and progress with organisational development. It is intended that this review will continue to form part of subsequent NB updates.

The descriptions draw upon information contained elsewhere (principally the Company Manual but do not repeat the full list of responsibilities and focus on the nuclear safety perspective.

3.4 Summary of Planned Organisation Design Changes The first draft version of the NB was submitted in April 2020 and it only covered Posts within the Environmental Baseline with NB roles. This issue of the NB builds on the previous version and represents SZC at June 2020 focusing on the organisation pre FID.

Since then, some activities have been completed and others are defining the phases of the Project.

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The Development Consent Order (DCO) application to build SZC Power Station was submitted to the Planning Inspectorate in May 2020.

A key driver for SZC is to replicate HPC as closely as possible, in order to leverage skills, experience and capability, By duplicating the HPC detailed design and adopting a systematic approach to capturing, quantifying and applying lessons learned, SZC will maximise the value gained from a ‘Next of a Kind’ (NOAK) series effect. Taking the HPC learning on board has identified opportunities to enhance and improve the delivery model for SZC, improving control of the schedule, costs, quality and nuclear safety for key SZC project phases, including the path to FID, FID to J0 and post J0. SZC will have the expertise from HPC and the new Technical Central Organisation (TCO) will provide NB and IC capability.

Sizewell C will be a standalone independent company from financial close. Within this standalone structure, EDF will be a minority shareholder and will continue to provide technical support services to SZC through its construction and operation. To achieve this financing and ownership arrangement, a new financing model is being developed for Sizewell C: the ‘Regulated Asset Base’ (RAB) model. An Information Memorandum IM) document is currently under development and it will be available in October 2020. SZC organisation structure and population will grow as the project secures the investment required and it moves to other phases.

To support the NB, a MoC process has been approved for SZC and the NB will be kept up to date to comply with Licence Condition 36. The Organisational Development (OD) Board was launched in May 2020 and it will provide Governance for NB arrangements for HPC and SZC

4 RESOURCING & THE NUCLEAR BASELINE

4.1 Resourcing Overview The overall resource requirements and future manpower needs within SZC are managed through the Company’s Resource Strategy [Ref 13] and supporting MTP for the period 2019 to 2021. One of the inputs to the strategy is the nuclear safety risks associated with the activities being carried out at each phase and the organisation, resources and competences needed to manage, direct and control work. The resource needs include consideration of Board capability in recognition of the key leadership and governance roles. The OD Board and Executive Team maintain an oversight of the delivery of the Resource Strategy and Plan as part of their assurance activities to challenge the developing organisation. The OD Board will also monitor the implementation of the Resource Plan and the continuing organisational development. During SZC development stage (pre FID), the workforce supporting SZC is made up of four main groups: o An employed workforce who are seconded directly from the EDF Group o People supplied though the Inter-Project Services Agreement (IPSA) with HPC

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o The Central Support Functions shared services of EDF UK Limited o Contingent workers from an approved framework of suppliers (embedded contractors)

The NB has been used as an input into the MTP and the Company’s resource planning process. This process assesses the estimated resourcing needs of the organisation to 2021. The headcount number for the pre FID organisation will continue to grow consistently to 2022 (currently 169 as data in June 2020 to approximately 220 employees up to December 2021) as no construction work will commence during this phase. Also, numbers on IPSA agreement approximately 23 up to 2022 (see Appendix A 1.3 Organisational Charts).. A reduction of NB roles to be allocated to Posts was expected at this phase of the project, in comparison to HC, due to the activities planned pre FID as well as aiming to simplify the NB approach for SZC taking lessons learnt from HPC. Also, technical and non-technical services will be provided via IPSA arrangements from HPC and TCO technical services for example. The resource strategy sets out core principles to guide appropriate resourcing decisions, e.g. collaborative and flexible approach towards resource sharing. These are high level and have been designed to be applicable across HPC, SZC and Nuclear Generation (NG). The TCO concept would deliver a solution for technical support for SZC that: delivers technical competency (nuclear, engineering and environmental) as part of the NB to each of the Licensees through the TSO which aligns resources from HPC and NGL into combined teams. As a future Licensee and Operator, SZC needs to set itself to comply with the IC requirements defined by the ONR and EA with respect to nuclear safety and environmental compliance. During SZC development stage (pre FID), the current organisation will evolve towards its final delivery model with clear accountabilities between Client and delivery (this is still work in progress). It is based on the lessons learnt from the HPC project to avoid duplication of efforts. The NB will be reviewed and updated to include Posts in the delivery organisation and potentially number of NB roles will change then. The delivery model will be organised in three defined layers:

- A Client responsible for Overall Project Assurance - A Project Delivery Organisation (PDO) responsible for the integration, coordination and acceptance across the delivery programmes and project lifecycles - Programmes responsible for the delivery of the project A key purpose of the Resource Strategy is to plan for mitigation of identified workforce risks. The new OD Board will complete routine review of workforce risks, escalating where applicable and identifying new risks. The new Nuclear Resource Hub will be responsible for the end-to-end recruitment for all permanent and embedded contractor requirements for both Nuclear New Build and Nuclear Generation. The Hub will provide a dedicated, in-house recruitment service to ensure Resource Plans are executed in line with the MTP. The Hub primary purpose is to plan ahead, analysing the skills required during construction through to commissioning and operations, ensuring that plans are in place to train or recruit the required

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workforce. This strategy sets out the standardised risk based approach to resource planning across the short, mid and long term. This enables integrated resource planning across HPC, SZC and NG. Detailed information on the Resource Strategy and implementation plans are not included in this NB document. These are included in the Resource Strategy Document.

4.2 The Nuclear Baseline and Contractors The Company recognises its responsibilities to maintain an intelligent undertaking of all SESHQ responsibilities. SZC’s policy is to meet its safety, environmental and NSL obligations through a capable team operating in accordance with approved quality arrangements. It will also draw on competent contractors whose skills complement and extend those embedded in the organisation. Where individuals are embedded in the SZC organisation and carry out a nuclear safety related role on behalf of the Company, they are considered to be part of the SZC Licensee Organisation and therefore on the NB. Contractors that do not meet the criteria for embedded contractors are overseen in line with the Company’s IC arrangements. The vulnerability assessment of the NB resource profile includes an assessment of the issues around the use of contractors within the Licensee Organisation. Within the current phase of the project SZC is making best use of the skills, capabilities and experience within the wider EDF in the UK. This work is being managed through an IPSA. Employees performing work under the IPSA agreement will be part of the SZC NB.

4.3 Role and Training Profiles The IAEA has defined competence as “the ability to put skills and knowledge into practice in order to perform a job in an effective and efficient manner to an established standard”. Training is fundamental to acquiring and maintaining the skills and knowledge needed to perform a job to defined standards and sustaining competence. A Company Procedure on the Management of Competency will cover development of competencies which individuals must possess in order to perform roles that can potentially impact on nuclear safety. The procedure provides the process for developing a list of training, experience and educational requirements associated with the role as well as the process for assessing individuals against these requirements. Section 2.1.3 summarises the methodology for categorisation of roles and allocation to the NB. Posts associated with RSR, Licence Condition & Committee membership, as detailed in the RSR & LC compliance matrix, have been given appropriate governance role and training profiles. The Nuclear Skill Alliance (NSA) function at EDF is leading a Competency Framework project to develop a consistent competency approach across NG, HPC and SZC. A programme of formal competence assessment will be available in the later part of 2020 and it remains the intention to complete the assessment of role holders by end 2020. The programme for formal competence assessment will also be reviewed and simplified taking learnings from HPC.

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4.4 Intelligent Customer As part of development and implementation of the Intelligent Customer (IC) Policy [Ref 14], SZC is putting in place a strong IC capability to support oversight of nuclear safety related activities. The allocation of IC practitioner roles (referred to as IC roles in this document) addresses the corporate IC capability in the context of nuclear safety. This ensures IC roles are in place in proportion to nuclear safety significance, so that the Company remains in control of work carried out by contractors with nuclear safety implications. IC responsibilities address the range of contract lifecycle stages and may be through technical, operational or managerial oversight for work carried out on SZC behalf by non-embedded contractors and external suppliers. The IC activities (taken from the NB role profile for IC Practitioner) include:  Support to decision making for when to use contractor services;  Specification of requirements;  Assessment of technical quality of tenders;  Active and rigorous monitoring and oversight of nuclear safety aspects of work being carried out by contractors including the management of change aspects in relation to nuclear safety;  Identification of the need to act upon the outcomes of the review of contractors’ work;  Assurance of the contractors’ management arrangements;  Evaluation of the quality of work undertaken by contractors;  Technical review of standards of nuclear safety achieved;  Interaction with contract organisations to maintain an appropriate level of SZC control; and,  Contributing to the acceptance of work on behalf of SZC through the appropriate processes and procedures.

For the pre FID organisation, Posts with NB responsibilities have been assessed and some roles have been identified as contributing to the IC capability for the project at this stage and therefore have IC roles associated with them. Allocation of IC roles has been determined on the basis of individual responsibilities. Individuals contributing to the IC capability are identified with an ‘IC’ flag against their post in the NB. Future versions of this document will need to consider the new TCO services and IC provided by this area. Design Authority (DA) teams which have an extensive IC capability requirement and this can be seen with the DA team having IC roles associated with posts across the technical areas. This will be defined as the delivery organisation is finalised in the coming months. Future NB versions will be updated as required.

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Some Executive Directors of SZC will also have IC roles; this is due to both the nature of the degree of contract oversight required and also as part of implementing the Company’s intended employment model. The Board training and competence demonstration arrangements will be developed to include the IC aspects of their roles and responsibilities. Training on IC roles and responsibilities will be part of the initial packages of training.

4.5 Succession Planning The Head of People is responsible for implementing and operating succession planning and contingency arrangements for:  Temporary Succession - individuals who could hold the role on an immediate but short-term basis if the incumbent unexpectedly cannot fulfil the required duties; and,  Planned Succession - individuals who would be suitable candidates to fill the role with suitable planned development.

Succession plans will be put together taking into account the likelihood of the loss of the current post holder, future personal development plans for the post holder and options to cover loss in the near and long-term. In the first instance, successors will be drawn from within SZC but consideration will be given to suitable successors from across the EDF family. Succession plans will be regularly reviewed by the People & OD Director and reported to the Board. In this period of organisational growth the challenge, in terms of capability, is to develop and populate the organisation with competent people in line with the needs of the business and activities being undertaken. The issue of succession planning will become more significant as the project develops but at this phase it is confined to contingency arrangements for the aspects set out below:  Key management, leadership and business critical posts;  Key safety, security and environmental related posts; and  IC roles and areas of singleton expertise not addressed through safety related post succession arrangements. The process of mapping the successors within the organisation for these key posts has already begun. In the period leading up to the award of the NSL, successors for NB posts / roles will be identified and in the meantime a mapping process will identify the short term ‘safe pair of hands’ contingency cover. Where embedded contractors are fulfilling NB roles, arrangements will be made for the transfer of knowledge to SZC from the individuals involved. In addition, consideration will also be given to permanent recruitment into those roles currently carried out by contractors.

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5 CURRENT NUCLEAR BASELINE

SZC’s NB has been developed in line with the Nuclear Industry Code of Practice. There are four elements required to articulate and demonstrate the information required of a successful NB, as explained in Table 3. Each of these requirements and how SZC meets these expectations are discussed in further detail in the following sections.

Elements of the Nuclear Scope Baseline Define The number of roles and consequently Posts required to support the delivery of SZC’s activities related to the NB Areas Justify How the NB meets the requirements of a capable organisation to achieve delivery of the activities related to the NB Areas at all times Status The Actual number of competent personnel that SZC has in place versus the defined as being required.

Vulnerability Assessment Reviews of the organisation / resource factors (e.g. vacancies, singleton SQEP) to assess for current of future weaknesses to achieving the delivery of the activities related to the NB Areas

Table 3 - Nuclear Baseline requirements breakdown

5.1 Nuclear Baseline definition The definition of the NB consists of the number of roles and associated Posts required to support the delivery of SZC activities covered by the NB Areas.

These NB roles are mainly associated with:

• compliance with nuclear safety, environment and security legislation for new reactor build across the Project; • nuclear safety related decision making; • nuclear safety governance; • setting policies and standards and developing the management system; • establishing systems for nuclear safety in the event of an emergency; and, • oversight of nuclear safety related activities delivered by others outside of the organisation

The MTP has been through substantive challenge and approval to ensure appropriate resource has been identified for this phase of the project (up to December 2021). A phased approach to recruitment has been identified within the MTP identifying a number of Posts and subsequent NB roles being required up to 2022. Work activities were reviewed and considered the skills and resources required to complete the work.

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Appendix A1.2 shows a breakdown of the NB roles by Posts. Appendix A1.3 shows the Organisational Charts (agreed at the MTP 2019 and reviewed recently in April 2020) reflecting the role allocation. They highlight the Posts with NB roles (red flag) and IC roles (yellow flag). The NB Database provides management information on Post holders.

Oversight of the compliance with LC and RSR requirements and key governance roles were part of the selection criteria to assign roles.

5.2 Nuclear Baseline justification

The NB organisation in place at 30th June 2020 has been reviewed against the defined NB need for the pre FID phase. This has been carried out using themes and questions to challenge the NB profile and identify strengths and weaknesses which are then considered.

Analysis included assessment against the NB measures which are a combination of leading and lagging indicators to aid management of the NB. Additional information was gathered through discussions with responsible leaders and it was taken through a challenge and verification process.

Such questions confirmed understanding of the following: • the rationale for confidence in planned resource levels; • any assessment and/or benchmarking that has been used to verify adequacy of planned resource levels; • how NB Roles and the activities they support are monitored; and • how SZC will identify if the organisation lacks capability or capacity to deliver the activities covered by the NB Roles.

For future versions of the NB, intelligent replication of Role and Training profiles from HPC will also support the justification of the SZC NB.

5.3 Nuclear Baseline status SZC’s NB status, for this version of the NB statement, shows the populated pre FID organisation against the defined NB.

The overall NB profile is summarised in Table 4 below with more detail being presented in Appendix A1.1. This profile is analysed further in section 5.4.

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Required by the end of Pre- Construction Filled as June 2020

Directorate NB Posts NB Roles NB Posts NB Roles Exec Team & Board 12 18 12 (100%) 18 (100%) Safety 6 26 2 (33%) 7 (27%) People & OD 1 3 1 (100%) 3 (100%) Project Services 2 6 1 (50%) 5 (83%) Supply Chain 1 1 1 (100%) 1 (100%) Engineering & Delivery 5 9 2 (40%) 3 (33%) Engineering Integration 6 13 3 (50%) 10 (77%) Total (rounded) 33 76 22 (67%) 47 (62%)

Table 4 – Overall NB Profile

 The MTP (2019-2021) has been the main source of information to confirm headcount across all teams in SZC. As this phase is evolving, some Posts are planned to be recruited in the second half of 2020 and throughout 2021 with critical roles being prioritised. Some NB Posts are still vacant and they will be filled in 2021. NB roles have already been allocated to these Posts.

 Intelligent duplication and lessons learnt from HPC’s approach to the NB were taken into account to create and simplify the NB. The intention was to reduce the number of NB roles, if appropriate and ensuring all NB areas are covered with the right capability. The review of the competency assessment process will take place in order to simplify this process too.

 All NB roles from HPC were reviewed against Posts in SZC. Only appropriate NB roles for SZC for the pre FID phase were selected to create the SZC NB roles list and database. This new NB list is made of 34 NB roles.

 Future versions of the NB Organisation will follow a systematic approach to be adopted, reviewed and refreshed as appropriate during implementation and future phases of the project. Recruitment will need to be prioritised to ensure the defined NB is adequate to deliver the planned activities covered by the NB Areas.

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5.4 Nuclear Baseline Vulnerabilities Assessment An analysis of SZC NB to identify vulnerabilities involves review of the NB statement alongside other key organisational and resource factors (e.g. vacancies, singleton NB roles etc.). This identifies current or potential weaknesses that may influence the delivery of activities delivered by NB role holders.

5.4.1 Assessment Approach Assessment of the NB for this issue drew on a range of sources:  Achievement against the NB measures;  High level analysis of the NB Reference (lower and upper limits) allows challenge of the profile within departments and teams and provides another view of the result of the association of role. This included consideration of fit with the Nuclear Organisational Design Principles and aspects such as span of control, NNB GenCo ownership etc; and,  Assessment of the allocation of NB roles to individuals and posts. This allows analysis to drill down to address aspects such as any gaps in competence or complement and assess the mitigation of these gaps.  Complement: Is there enough resource in place? Are there any singleton roles and if so what is the significance of these? What is the significance of any vacancies and are these being pursued actively? How is non-embedded resource used?  Competence: Are there any overall competence issues? Is corporate capability such as IC appropriately considered?  Significance of any gaps: Are mitigation arrangements suitable and sufficient? Are actions identified to improve the NB for this and future stages?

5.4.2 Summary of Vulnerability Assessment Individual vulnerabilities are recorded in the NB Database along with mitigating factors. Appendix A1.2 contains a full listing of the NB Posts and Roles with a breakdown of data according to Directorate and departments. The data is presented in a number of summary tables and charts. This section reports against the NB measures and the results of the vulnerability assessment.

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Nuclear Baseline Measures

Measure Pre FID Commentary

COMPLEMENT

% NB Posts filled 67% MTP shows when all Posts will be filled by 2022. Vacancies within the Safety team planned to be recruited mostly in 2021. Some vacancies within the Engineering teams have been offered to candidates. % NB roles fulfilled 62% Not all NB Posts have live NB roles at this point in the Pre-Construction phase (June 2020)

A review of NB roles within DA to be completed. COMPETENCE

% NB Posts with Formal data to follow SZC is keen to simplify the competency assessment competence needs gap approach so this is a key area to develop in 2020 NSA is developing a common approach to

competencies and a Competency Framework will be available to support SZC, HPC and NG % NB roles with training profiles Formal data to follow Training profiles will be developed as per comments above IC CAPACITY % NB Posts with IC roles 50% This proportion reflects the assessed current need

% Posts with IC roles 60% IC requirement becomes live later in this phase Fulfilled (recruitment plan in place) LICENCE ORGANSIATION

% NB Posts with NB 64% More than half of the NB Posts are ‘local employees’ roles held by non embedded staff % NB Posts fulfilled by 36% There are 12 Posts in the NB held by contract staff. Embedded Contractors Confirmation. Initial checks indicate that most of these will meet the criteria for embedded status.

Table 5 - Nuclear Baseline performance summary

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The SZC Organisation

The SZC project will not see a rapid growth of the organisation during pre FID. More than 70% of the NB roles are already filled and the rest will be filled in 2021. The next version of the NB will include post FID NB roles so the numbers will increase as the organisation grows. Figure 8 below illustrates how the NB organisation has been populated over this period.

Figure 8 Nuclear Baseline Holder Growth

Nuclear Baseline by Team

Exec & Board and Directors Team

Oversight of and responsibility for all licensed and permitted activity of the Company resides in the Board. The Board is responsible for ensuring compliance with all statutory and regulatory obligations.

13 Posts are associated with the NB in the Executive and the SZC Leadership Team.

Post types associated with the NB in the team are:  Managing Director

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 Director (Multiple specialities)  Independent Non-Executive Director  Company Secretary  Chief Financial Officer

The NB roles associated to the Executive and Board Team (including Directors) are: 130 - Nuclear Licensed Board Member 029 - Intelligent Customer Practitioner 114 - Nuclear Governance 145 - Nuclear Engineering 83 - Safety Director

The current NB requirement the Nuclear Engineering and Safety Director roles are set at 1 The Engineering and Safety Director are responsible for several Licence Condition requirements and the impact on nuclear safety, environment, security and quality.

The current NB requirements for Intelligent Customer Practitioner role is set at 4

On review of the NB roles for the Supply Chain Director with senior stakeholders, it was decided that competency requirements were not suitable for this Posts as the Safety Director and Engineering Director will be the Posts making the Quality and Technical decisions. The Supply Chain Director will hold the IC role.

The Board executes its responsibilities formally through a number of governance committees. These are described in the Company Manual. The governance committees all meet regularly and have clear terms of reference. They report to the Board on matters of note and key decisions

The SZC Lead Team provides a further level of leadership to the project. There is significant overlap with the membership of the executive team to ensure that the two leadership teams are aligned.

 This area is considered GREEN with low vulnerability.

Safety

The Safety team brings together the parts of the organisation that have a responsibility for establishing the policies and standards around safety, environment, security and quality. This team will become the Quality and Assurance function post FID.

4 NB Posts (Quality Manager, Licencing Manager, INA Manager and Security Manager) are currently vacant and recruitment is planned to fill the Posts in 2021 when the activity will need to be performed.

14 NB roles will be associated to the above Posts when recruited. The current requirement for these roles is 1.

29 - Intelligent Customer

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113 - IMS Compliance 139 - Site Quality Assurance 190 - Quality Lead 114 - Nuclear Governance 086 - Nuclear Licence Condition Compliance Adviser 105 - Independent Assessor: Generic 109 - Independent Assessor: Industrial Safety 110 - Independent Assessor: Quality Assurance 111 - Independent Assessor: Environmental 222 - Independent Site Inspector 091 - Nuclear Security & Governance 092 - Security Management: Personnel Security 094 - Security Management: Physical Security

The Environment Team is responsible for setting Policy and Standards in the areas of Environment, Sustainability, Decommissioning, Emergency Preparedness and Business Continuity. Alongside the Technical Directorate, the Environment Team are also responsible for environmental design, review and acceptance. The team is also responsible for securing the required environmental permits to support the project execution and operational arrangements.

The Environmental Manager and the Radiological Environment Lead are the two Posts with NB roles. The Radioactive Substances Advisor role and IC role have been allocated to both Posts. The Conventional Environment Lead holds an IC role that it is not NB.

The NB roles associated to this team are: 29 - Intelligent Customer 9 - Radioactive Substances Advisor 14 - Decommissioning Management 1 - Control of Org Change Co-ordinator 204 - Environmental Leadership

The rest of the Posts within this team lie outside the scope of the NB.

 This area is considered GREEN with low vulnerability.

Engineering

The Engineering Directorate NB is separated into the following areas:

 Engineering and Delivering - 5 Posts are associated with the NB in this team (including Programmes’ leads)

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 Engineering Integration - 6 Posts are associated with the NB in team

They provide control and assurance of the quality aspects of the construction through the IC oversight of Construction activities.

12 NB roles exist as singleton resources as the current requirement for these roles is 1. However, the vulnerability in these areas is low as the teams need to be resourced and this phase does not require more Posts with these roles.

114 - Nuclear Governance 125 - Project Management 089 - CDM Management: Engineering 103 - Design Gatekeeper 114 - Nuclear Governance 170 - Owner Review Technical Management 172 - Configuration & Modification Management 173 - Interface Management 171 - Engineering Coordination 032 - Safety Case Overview 018 - Safety Case Engineer 029 – Intelligent Customer

TCO will lead the assurance of the design for SZC. The DA will also own the process for the control and implementation of design and safety case changes. The DA will manage the design change process and this will be implemented on site.

The above NB roles and NB roles currently allocated to DA (see list below) will be review as part of the next version to include the post FID delivery organisation and the development of DA requirements within the Client organisation.

029 - Intelligent Customer Practitioner 023 - Design Authority Branch Manager 016 - DA Engineer Generic 114 - Nuclear Governance 145 - Nuclear Engineering 017 - Fault Studies Specialist 044 - Severe Accident Specialist 043 - Criticality Specialist 042 - Reactor Physics Specialist 022 - Design Authority Team Leader

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048 - Fuel Design & Management Specialist 045 - Thermal Hydraulics Specialist 047 - Radiological Consequences Specialist 044 - Severe Accident Specialist 128 - Spent Fuel Management 050 - Crane Specialist 032 - Safety Case Overview 052 - Human Factors Lead 031 - Probabilistic Safety Assessment (PSA) Specialist 019 - Hazards Engineer 073 - Structural Assessment Specialist 070 - Corrosion Specialist 183 - Equipment Qualification Engineer 075 - Inspection Specialist 072 - Materials Specialist 074 - Welding Specialist

There are vacancies in both of these teams at the moment. Some jobs have been offered to candidate and other Posts will need to be filled in 2021.

The rest of the Posts within this team lie outside the scope of the NB.

 This area is considered GREEN with low vulnerability.

Finance

Finance as a team does not appear on the NB. Currently, the CFO holds the Nuclear Licensed Board Member role in line with the requirements of LC 6.

The Project Services team currently reports to the CFO in the pre FID organisation. The Head of Project Services and the IT Service Manager are the two Posts in the team with NB roles. The IT Service Manager only has the IT Service Management role associated to the Post. The other NB roles below (including Information Security) are associated with the Head of Project Services and the current requirement for these roles is 1 so the vulnerability is low.

166 - IT Service Management 142 - Documentation Management 029 - Intelligent Customer 114 - Nuclear Governance 093 - Security Management: Information Security

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The rest of the Posts within this team lie outside the scope of the NB.

 This area is considered GREEN with low vulnerability. People & OD

The People & OD Director is responsible for all people policy matters in HPC and SZC during the pre FID phase. A People & OD Director will be recruited for SZC to support the future delivery organisation.

The Head of People for SZC has nuclear safety related responsibilities in relation to the processes for resourcing and the maintenance of capability in line with the requirements of LC 36 and RSR Permit conditions. Also, the Organisational Development team in HPC will provide support in activities related to Organisational Capability (MoC and NB matters for example) via the IPSA arrangements and this is why the IC role has been added to this Post so the vulnerability is low. This provides the support to the Head of People as a singleton resource. This approach will need to be review in post FID phases as this team’s responsibilities change to support the organisation.

This NB roles associated to this Post are: 1 - Control of Org Change Co-ordinator 114 - Nuclear Governance 29 - Intelligent Customer

The rest of the Posts within this team lie outside the scope of the NB.

 This area is considered GREEN with low vulnerability.

Supply Chain

The Supply Chain team ensures commercial arrangements between SZC and its supply chain are aligned to the project delivery model, reflect a fair balance of risk and incentivise a ‘Best for Project’ decision environment.

In terms of nuclear safety responsibility, the more significant NB role lie in Supply Chain Director as a key part of activating and coordinating the IC oversight. One more member of the Supply Chain team will act as a support IC role to provide contingency if required and avoid a singleton issue. The NB for this team looks different from HPC and the decision was made following several discussions at Exec level no to include Supply Chain positions on the NB.

Supply Chain ensures they have the right processes, the right capability and the appropriate governance working and work with the Engineering and Quality teams. No other activities performed by Supply Chain that can affect nuclear safety. All SZC decisions are ratify by the Board and Advisory Committee.

The rest of the Posts within this team lie outside the scope of the NB.

 This area is considered GREEN with low vulnerability.

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The rest of Teams in SZC lie outside the scope of the NB.

Complement

 All Directorates including the Executive and Board, have been assigned NB roles. The Posts within the Executive and Board Team (and various Directors for each Team) cover a third of the NB roles in SZC with clear focus on compliance with regulators and governance at this phase.

 Less than a quarter of the Posts that currently make the SZC project have NB roles associated with them. This indicates the type of activities the project is focusing on are different to the HPC project at the same milestone. Limited delivery activities as construction has not commenced (no construction to start before FID). Further detail on each Team’s NB assessment later in this section.

 Some areas for concern at this stage is that some NB roles are only associated with one individual which can bring singleton issues. Also, more than one or two NB roles (in some cases five NB roles) are associated with one individual. This could be a potential workload risk but the current data shows that they can deliver them effectively during this phase.

 The current assumption that TCO will provide the technical support during the future phases of the project. Therefore the NB roles and responsibilities will be owned and performed by this team. 26 NB roles from HPC are assigned to Posts within the Design Authority teams and they will need to be defined for the SZC post FID organisation

 Active recruitment plans are in place to filed critical Posts.

Competence

 The NSA team is leading a Competency Management project to establish an effective and a common approach to competency management across the nuclear business (HPC, NG and SZC, including the new TCO).

 The current competency assessment process taken from HPC is complicated and time consuming. The aim is to simplify this process. Then, training profiles will be developed to support the above and training will take place at all levels of the organisation (including IC training).

 This is an area for concern at the moment regarding the NB as time scales are tight. However, temporary support from HPC (and new TCO) provides highly technically capable individuals in teams such as DA as well as People & OD. Overall the breadth and depth of NB capability currently matches the project’s need.

Intelligent Customer Capability

 IC capability is structured from the Board level down into the individual teams to provide an organisation that understands its operations and the services and activities for which is it responsible for.

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 16 individuals are carrying out the role of IC Practitioner. It is judged that at this stage of the project, the spread and coverage of IC Practitioners is sufficient to enact the corporate IC Capability

 It is the intention that individuals will be seconded into NNB GenCo from EDF plc and EDF SA. With the IPSA arrangements NB roles are assigned to staff and embedded contractors in HPC, and SZC needs to ensure IC capability is developed.

 SZC is a ‘second of a kind project’ and the engineering safety case decisions will be made by the new TCO organisation so SZC will need to build the right SZC IC capability. Moving to future phases, IC roles will need to be reviewed alongside with the services and resources provided by TCO.

5.5 Actions for the Future The actions below address the key issues raised through the initial assessment of the NB profile and associated vulnerabilities. The detailed action plan will also reflect the wider NB roles that need to be mapped and the lower level improvement activities not listed here. Key actions include: a) Create a detail plan with deliverables to implement, maintain and improve the NB (to include feedback from ONR and AE on this version of the NB ) and share with key stakeholders across SZC to raise awareness of the NB; b) Establish KPI targets for continuous improvements of the NB and produce regular reports on progress; c) Establish processes and procedures to support NB (MoC, Role Training Profiles, Competency assessment); d) Transfer existing NB Database (currently spreadsheet) to a formal system (MS Access or similar) and Organisational Charts (currently PowerPoint) learning from HPC; e) The recruitment plan for critical Posts should continue to be pursued and kept under review; f) Succession plans for posts with NB roles should be developed; g) Post FID NB version: commence the review of all NB roles against the criteria set out for the delivery model and future phases; h) Address organisational development in future issues of the NB;

The actions above will be incorporated into the next version of the NB Statement in October 2020.

6 RECORDS

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NB roles will be maintained as a permanent record. The Database provides the live record of the NB roles and associated posts and is not required to be a permanent record. The Database will have the ability to record the status of roles and posts at points in time.

7 DOCUMENT REVIEW PERIOD The NB will be considered for updating: • Prior to a change in lifecycle phase; • As part of the ongoing MoC process; • At annual review; and • Where the OD Board or other governance body consider that the NB requires review for update for any other reason The NB Database will be maintained and it will present the current status of NB Posts and roles within the organisation.

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APPENDIX A – THE NUCLEAR BASELINE PROFILE A 1.1 Data Headlines Employment type analysis

NB Post Analysis

NB NB Post Candidate NB Post Analysis Post Fulfilled selected % Filled Gap Exec Team & Board / Directors 12 12 0 100% 0 Safety 6 2 0 33% 4 People & OD 1 1 0 100% 0 Project Services 2 1 0 100% 1 Supply Chain 1 1 0 100% 0

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Engineering & Delivery 5 2 1 60% 2 Engineering Integration 6 3 2 83% 1 TOTAL 33 22 3 82% 8

NB Role Analysis

NB Role Analysis Required Fulfilled % Filled RAG Mitigation Exec Team & Board / Directors 18 18 100% Safety 26 7 27% People & OD 3 3 100% Project Services 6 5 83% Supply Chain 1 1 10% Engineering & Delivery 9 3 33% Engineering Integration 13 10 77% Total 76 47 62%

A 1.2 Report from the NB Database – role and post associations

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NB Role Directorate NB Post NB Role Upper Lower Fulfilled RAG Mitigation Exec Team & Board 029 - Intelligent Customer Practitioner 1 1 Y Exec Team & Board Managing Director 130 - Nuclear Licensed Board Member 1 1 Y Exec Team & Board 029 - Intelligent Customer Practitioner 1 1 Y Exec Team & Board 114 - Nuclear Governance 1 1 Y Exec Team & Board Engineering & Delivery Director 145 - Nuclear Engineering 1 1 Y Exec Team & Board Chief Financial Officer 130 - Nuclear Licensed Board Member 1 1 Y Exec Team & Board Financing & Regulation Director 130 - Nuclear Licensed Board Member 1 1 Y Exec Team & Board CGN Director 130 - Nuclear Licensed Board Member 1 1 Y Exec Team & Board Non-Executive Director 130 - Nuclear Licensed Board Member 1 1 Y Exec Team & Board Non-Executive Director 130 - Nuclear Licensed Board Member 1 1 Y Exec Team & Board Non-Executive Director 130 - Nuclear Licensed Board Member 1 1 Y Exec Team & Board Company Secretary 130 - Nuclear Licensed Board Member 1 1 Y Executive Director People and OD Director 114 - Nuclear Governance 1 1 Y

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NOT PROTECTIVELY MARKED Executive Director 83 - Safety Director 1 1 Y Executive Director 114 - Nuclear Governance 1 1 Y Executive Director 130 - Nuclear Licensed Board Member 1 1 Y Executive Director Safety Director 29 - Intelligent Customer 1 1 Y Safety 29 - Intelligent Customer 1 1 N Safety 113 - IMS Compliance 1 1 N Safety 139 - Site Quality Assurance 1 1 N Safety 190 - Quality Lead 1 1 N Safety Quality Manager 154 - Construction management 3 1 1 N Safety 29 - Intelligent Customer 1 1 N Safety 114 - Nuclear Governance 1 1 N Safety Licencing Manager 086 - Nuclear Licence Condition Compliance Adviser 1 1 N Safety 105 - Independent Assessor: Generic 1 1 N Safety 109 - Independent Assessor: Industrial Safety 1 1 N Safety 110 - Independent Assessor: Quality Assurance 1 1 N Safety 111 - Independent Assessor: Environmental 1 1 N Safety 222 - Independent Site Inspector 1 1 N Safety INA Manager 114 - Nuclear Governance 1 1 N Safety 29 - Intelligent Customer 1 1 N Safety 114 - Nuclear Governance 1 1 N Safety 091 - Nuclear Security & Governance 1 1 N Safety 092 - Security Management: Personnel Security 1 1 N Safety Security Manager 094 - Security Management: Physical Security 1 1 N Safety 29 - Intelligent Customer 1 1 Y Safety 9 - Radioactive Substances Advisor 1 1 Y Safety 14 - Decommissioning Management 1 1 Y Safety Environmental Manager 1 - Control of Org Change Co-ordinator 1 1 Y NNB Generation Company (SZC) Limited. Registered in England and Wales. Registered No. . 09284825 Registered office: 90 Whitfield Street, London W1T 4EZ Page 46 of 67

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NOT PROTECTIVELY MARKED Safety 204 - Environmental Leadership 1 1 Y Safety 29 - Intelligent Customer 1 1 Y SZC Radiological Environment Lead Safety Radioactive Substances Advisor (9) 1 1 Y People & OD 1 - Control of Org Change Co-ordinator 1 1 Y People & OD 114 - Nuclear Governance 1 1 Y People & OD Head of HR 29 - Intelligent Customer 1 1 Y Project Services 166 - IT Service Management 1 1 Y Project Services 142 - Documentation Management 1 1 Y Project Services 29 - Intelligent Customer 1 1 Y Project Services 114 - Nuclear Governance 1 1 Y Project Services Head of Project Services/ IT Lead 093 - Security Management: Information Security 1 1 Y Project Services IT Services Manager 166 - IT Service Management 1 1 N Supply Chain Senior Supply Chain Lead 29 - Intelligent Customer 1 0 Y Engineering & Del. 114 - Nuclear Governance 1 1 N Engineering & Del. Engineering Director 145 - Nuclear Engineering 1 1 N Engineering & Del. Civils Programme Delivery 114 - Nuclear Governance 1 1 Y Engineering & Del. Manager 125 - Project Management 1 1 Y Engineering & Del. 114 - Nuclear Governance 1 1 N Engineering & Del. NI Programme Delivery Director 125 - Project Management 1 1 N Engineering & Del. 114 - Nuclear Governance 1 1 N Engineering & Del. CI BOP Programme Manager 125 - Project Management 1 1 N Engineering & Del. Engineering Integration Lead 29 - Intelligent Customer 1 1 Y Engineering Int. 089 - CDM Management: Engineering 1 1 Y Engineering Int. 103 - Design Gatekeeper 1 1 Y Engineering Int. 114 - Nuclear Governance 1 1 Y Engineering Int. Replication Lead 170 - Owner Review Technical Management 1 1 Y Engineering Int. Configuration Engineer 172 - Configuration & Modification Management 1 1 Y NNB Generation Company (SZC) Limited. Registered in England and Wales. Registered No. . 09284825 Registered office: 90 Whitfield Street, London W1T 4EZ Page 47 of 67

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NOT PROTECTIVELY MARKED Engineering Int. 173 - Interface Management 1 1 Y Engineering Int. 171 - Engineering Coordination 1 1 Y Engineering Int. 114 - Nuclear Governance 1 1 Y Engineering Int. 032 - Safety Case Overview Engineering Int. SZC Safety Case Site Manager 018 - Safety Case Engineer 1 1 Y Engineering Int. SZC Safety Case Correspondent 29 - Intelligent Customer 1 1 N Mechanical Engineer Engineering Int. Correspondent 29 - Intelligent Customer 1 1 N Engineering Int. Civil Engineer Correspondent 29 - Intelligent Customer 1 1 N

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A 1.3 Organisational Charts

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NNB GENERATION COMPANY (SZC) LTD

COMPANY DOCUMENT MANAGEMENT SYSTEM MANUAL - SIZEWELL C

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TABLE OF CONTENTS

INTRODUCTION ...... 5 1.1 Scope ...... 5 1.2 Requirements ...... 5 1.3 Stakeholders ...... 5 1.4 Accountability, Responsibility and Authority ...... 6 1.5 References and Definitions ...... 6

INTEGRATED MANAGEMENT SYSTEM COMPOSITION ...... 7 2.1 Document Sharing...... 8 2.2 Content ...... 9

PROCESS FRAMEWORK ...... 10 1.1 Process Levels ...... 10 1.1.1 Process Categories ...... 10 3.1 Process Levels ...... 10 3.2 Business Processes ...... 11 3.2.1 Procedures ...... 12 3.2.2 Work Instruction ...... 12 3.3 Process Interaction ...... 12 3.4 Outsourced / Contracted Processes ...... 13 3.5 IMS Governance ...... 13 3.6 Management System Governance Group ...... 13 3.6.1 Responsible Manager ...... 13 3.6.2 Process User ...... 13 3.6.3 Procedural Use and Adherence ...... 13 3.6.4 Procedure Review Periods ...... 14 A.1 Appendix A ...... 15 A1. Process Groups ...... 15 A1.1. Management Processes ...... 15 A1.2. Safety Leadership & Management ...... 15 A1.3. Governance...... 15 A1.4. Business Planning & Investment...... 16 A1.5. Assurance ...... 16 A1.6. Core Processes ...... 17 A1.7. Project Management ...... 17 A1.8. Design 18

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A1.9. Procure 18 A1.10. Manufacture ...... 19 A1.11. Construct ...... 19 A1.12. Commission ...... 20 A1.13. Operate ...... 20 A1.14. Decommission ...... 21 A1.15. Consents, Permits & Licences ...... 21 A1.16. Support Processes ...... 22 A1.16.1. Documents & Records...... 22 A1.16.2. People ...... 22 A1.16.3. Training & Qualification ...... 23 A1.16.4. Communications ...... 23 A1.16.5. Finance ...... 24 A1.16.6. Information Management ...... 24 A1.16.7. Properties & Facilities ...... 25 A2. Definitions ...... 25 A2.1. Policy 25 A2.2. Policy Practice & Guidelines ...... 25 A2.3. Executive Committee Terms of Reference ...... 25 A2.4. Process Group and Process...... 25 A2.5. Procedures ...... 26 A2.6. Work Instruction ...... 26 A2.7. Business Forums Terms of Reference ...... 26 A2.8. Specification ...... 26 A2.9. Standard ...... 26 A3. Description of Elements...... 26 A3.1. Organisational Note ...... 26 A3.2. Manual 27 A3.3. Briefing 27 A3.4. Guide 27 A4. Ownership ...... 27 A4.1. Process Owner ...... 27 A4.2. Process Lead ...... 28 A4.3. Policy Owner ...... 28 A4.4. Policy Lead ...... 28 A4.5. Legislation Category Owner ...... 28 A4.6. Legislation Category Lead ...... 29

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INTRODUCTION

1.1 Scope This Management Systems Manual explains how the management processes for NNB GenCo (SZC) are to be implemented. It describes the Integrated Management System (IMS) which is the tool used to ensure NNB GenCo (SZC) is able to act as an intelligent customer to design, procure, construct, commission, operate and eventually decommission Sizewell C nuclear power plant. This will be executed safely and reliably to quality, time, and cost in accordance with the Company Manual (Ref. 1) the Nuclear Baseline statement (Ref 2) and the company Quality Policy (Ref 3).

1.2 Requirements The IMS satisfies and demonstrates compliance with applicable laws and regulation as well as with the following international standards:  IAEA Safety Requirements GSR-2 -Leadership for Management and Safety (Ref. 4).  BS EN ISO 9000:2015- Quality Management Systems (Ref. 5).  BS EN ISO 14001:2015 - Environmental Management Systems (Ref. 6).  BS EN ISO 45001:2018 – Occupational Health and Safety Management Systems (Ref. 7).  Nuclear Site Licence Conditions (Ref. 8)  Environmental Permitting Regulations (Ref. 9)  Guided by BS EN ISO/IEC 27001 – Information Security (Ref. 10).

1.3 Stakeholders Stakeholder requirements will be incorporated into the activities and interactions of the processes and procedures within the Integrated Management System. These include;  owners and investors – who expect high standards of safety and a return on investment;  customers – who in the current pre-operational phase of the project are our owners;  the public and communities within which we operate – who expect safe and environmentally sound operation and good corporate citizenship;  employees – who expect trust, recognition and reward and who contribute to and share in NNB GenCo (SZC)’s success and whose training, development and participation will promote that success;  regulators – who expect safe, secure and environmentally sound build, operation and decommissioning;  World Association of Nuclear Operators  HM government – who expect us to provide safe reliable energy;  Pressure groups and Non-Government Organisations – who expect us to engage with them;  The Responsible Designer – who expect us to succeed and want to have a good relationship with us;  Suppliers of equipment or services (e.g. reactors, components, fuels, fuel cycle services etc.) – who expect us to succeed and want to have a good and profitable relationship with us;  The media – who expect timely, open and honest information;

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 Trades Unions – who expect us to provide open and fair working relationships with our employees and suppliers.

1.4 Accountability, Responsibility and Authority The Finance Director is responsible for ensuring that the IMS is effective in meeting the business objectives, and will ensure that:  The development, implementation and continual improvement of the Integrated Management System is maintained,  the performance of the Integrated Management System, including its influence on safety and safety culture is monitored,  customer requirements are addressed throughout the organisation,  conflicts between customer requirements and the processes of the IMS are resolved; and  performance and compliance is assured through a programme of independent assessment. NNB GenCo (SZC) will retain overall responsibility for the Integrated Management System in accordance with the Intelligent Customer policy (Ref 11).

1.5 References and Definitions

Ref Title Location NNB Document No. 1 NNB GenCo (SZC) Company Manual EDRMS 100200192

2 NNB GenCo (SZC) Nuclear Baseline Statement EDRMS 100200200

3 NNB GenCo (SZC) Quality Policy EDRMS 100200187

https://www- IAEA, Leadership and Management for Safety, IAEA Safety External 4 pub.iaea.org/MTCD/Publication Requirements No. GSR-Part 2, 2016 Website s/PDF/Pub1750web.pdf

External https://www.iso.org/standard/4 5 BS EN ISO 9000:2015 Quality Management Systems Requirements Website 5481.html

BS EN ISO 14001:2015 Environmental Management Systems – External https://www.iso.org/standard/ 6 Requirements with guidance for use Website 60857.html

https://www.iso.org/iso-45001- BS EN ISO 45001:2018 Occupational Health and Safety – Requirements External 7 occupational-health-and- with guidance for use Website safety.html

External http://www.onr.org.uk/silicon. 8 ONR Nuclear Site Licence Condition Handbook Website pdf

http://www.legislation.gov.uk/ External 9 Environmental Permitting (England and Wales) Regulations 2010 ukdsi/2010/9780111491423/co Website ntents

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Ref Title Location NNB Document No. BS EN ISO/IEC 27001: 2005 Information Technology – Security External https://www.iso.org/standard/ 10 Techniques – Information Security Management Systems – Website 54534.html Requirements

11 NNB GenCo (SZC) Ltd Intelligent Customer Policy EDMRS 100200193

Term / Abbreviation Definition EDRMS Electronic Documents & Records Management System

EPC Engineering, Procurement & Construction

EPR™ The Pressurised Water Reactor developed and trademarked by AREVA

GDA Generic Design Assessment

GL General Ledger

HPC Hinkley Point ‘C’

HSE Health and Safety Executive

IAEA International Atomic Energy Agency

IMS Integrated Management System

INSAG International Nuclear Safety Advisory Group

IT Information Technology

MSM Management System Manual

NNB GenCo NNB Generation Company (HPC) Limited and NNB Generation Company (SZC) Limited

NSL Nuclear Site Licence

ONR Office for Nuclear Regulation

ONR(CNS) Office for Nuclear Regulation (Civil Nuclear Security)

RSR Radioactive Substances Regulations

Safety Includes nuclear, radiological, industrial, environmental, health and security related safety

SZC Sizewell C

PEP Project Execution Plan

INTEGRATED MANAGEMENT SYSTEM COMPOSITION

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The IMS integrates structure, resources and processes into one coherent system to enable the organisation’s objectives to be achieved. The Management System Manual documents and describes how the IMS achieves its objective with a specific focus on processes and procedures. The IMS sees increasing level of detail down through the system from the strategic apex to the lowest level of business activity, and provides increasing levels of understanding from the top level frameworks to detailed explanation provided in guidance documents.

2.1 Document Sharing SZC shares the basic process flowcharts and origin data with the HPC project at this stage of project development, in a “Mega” data store, (and hence automatically gathers updates based on OPEX directly from HPC experience). Each procedure then can be accessed via a portal which is discrete per project, and automatically adds the necessary project branding to the process documentation. Each project has an intelligent customer document owner for each procedure, and hence assures that any document change still maintains the appropriate integrity and relevance to the projects. It is possible that due to the maturity of the HPC project, then SZC will operate to a previous issue of the documentation, reflecting the difference in project programme timescales. This is catered for by having a part of the system that is dedicated to SZC specific procedures. The structure of the process is shown in Figure 1 below.

Figure 1- IMS Database

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2.2 Content The IMS structure comprises of seven layers, which provide increasing levels of detail as one descends through these levels. The top three levels define the strategic apex of NNB GenCo (SZC). The bottom four levels define the core operational processes, which are designed around the business objectives. The key elements of the IMS hierarchy (Figure 2) can be categorised as:  Overview (Framework) – presents the overall structure of the Company’s management arrangements, established on the behalf of and approved by the Managing Director and the Executive Team.  Define (What) – These describe what is expected or what is to be undertaken and enable people to be put to work by providing a clear explanation of what is required.  Describe (Why & How) – These parts provide context and detail to enable individuals to understand what is expected and why, along with more detailed explanations and guidance on how to undertake activities.

Figure 2, IMS hierarchy.

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PROCESS FRAMEWORK

1.1 Process Levels The below section describes in detail all process levels which establish the process framework in which all the lower level processes, procedures and work instructions will be developed and managed. The full process framework, including detailed descriptions of the processes can be found on the IMS Portal IT System.

1.1.1 Process Categories Three process categories exist within the framework:  Core Processes are made up of a high-level value chain of Project Development, Project Delivery, and Post Construction. Core Processes organise the businesses key activities linked to the product and are typically expressed as a value chain, taking an input, and transforming it into a value adding output.  Fundamental Processes drive, govern and assure all other processes in the organisation. Fundamental Processes can be described as management processes.  Support Processes are enablers for the core and fundamental processes. The support processes provide a foundation for executing the SZC Project.

3.1 Process Levels Process categories divide into process groups (e.g. Design to Accept, Corporate Governance, Business Improvement) which provide a high-level view of the key activities the company needs to perform to meet its strategic aims. This includes the core processes that have been identified as key to meeting the NNB GenCo (SZC) mission as well as the Support and Fundamental processes required to be able to carry them out in a controlled and effective way. Process groups are sometimes termed Level 1 processes. The detailed descriptions of individual process groups are not within this document; the descriptions are maintained at the point of use on the IMS Portal IT system.

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Figure 3: SZC GenCo Process Groups. Note that Civils, Manufacture & Erection, Systems Completion, and Commissioning are not Process Groups, they are the phases that make up the Project Delivery Model and are presented here to show the alignment between the Project Delivery Model phases and the Process Groups.

3.2 Business Processes Process groups divide into several business processes which in their totality deliver the objective of the process group. These are generally presented in the form of a value chain / lifecycle, as illustrated in Figure 4 below. Business processes are sometimes termed Level 2 processes. These are described in Appendix A. In some instances, due to complexity or scale of activities, it is necessary to break a business process down into further sub business processes (i.e. level 3 processes). These sub business processes will form a logical value chain of the overall capability being delivered by the business process. Sub business processes are not described further within this document.

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Figure 4 Example of the “Design to accept” Process Group.

3.2.1 Procedures Processes are executed by procedures, which describe how to consistently and accurately undertake an activity to deliver the required outcome. They capture step by step instructions and are used to assure effective and safe working practices are in place. These procedures may be any of the following type:  Company Procedure  SZC Site Safety procedure  Contractors Handbook Procedure  Operational Procedure Company Procedures are themselves developed using procedures to ensure consistency.

3.2.2 Work Instruction A work instruction is a step-by-step guide to performing an activity within a procedure e.g. how to enter data in a system. Work instructions are developed and managed by the team responsible for performing the task.

3.3 Process Interaction To ensure effective interaction between interfacing processes, the IMS will allow NNB GenCo (SZC) to.  Document the inputs and outputs between processes, the providers and the recipients, the responsibilities and the method of data or product transfer.  Ensure effective communication and understanding between all process stakeholders.  Apply controls to ensure the effectiveness of process interactions.  Monitor and review process performance through day to day monitoring and periodic self and independent assessment including process interaction assurance; and  Improve process interactions where non-conformances and preventive actions have been identified.

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3.4 Outsourced / Contracted Processes NNB GenCo (SZC) retains overall responsibility for outsourced processes and retains controls over these processes. The controls have been defined using the guidelines of IAEA GSR 2 (Ref.4) and the requirements for NNB GenCo (SZC) as a nuclear site licensee to act as an Intelligent Customer. The requirements for, and controls on, the outsourced processes for Tier 1 construction contractors are described in their relevant contracts and supporting contract appendices as well as NNB GenCo (SZC) company procedures where a required input from, or output to, an external Contractor is defined.

3.5 IMS Governance Governance arrangements are in place to ensure the integrity and quality of the IMS is maintained and that the organisation has processes and procedures in place that are suitable and effective in delivering the Company’s objectives.

3.6 Management System Governance Group The Management System Governance Group is a joint HPC/SZC group responsible for day to day governance of the Management System, including:  Monitoring Management System metrics to identify weaknesses and significant risks and act accordingly.  Maintaining oversight of the forward plan for Management System development and improvement  Reviewing individual arrangements where greater governance is required – e.g. when developing safety critical arrangements or companywide documents that may have a large impact.  Monitoring compliance with agreed international standards and associated accreditation and identify and initiate actions to address any compliance issues with licences and permits.

3.6.1 Responsible Manager The primary responsibility of the responsible manager is to ensure company procedures can and are being used by their team and that staff are trained and competent.

3.6.2 Process User The process user must ensure they understand the appropriate procedure, inform their responsible manager if they have any concerns with undertaking the associated activities and comply with what has been specified

3.6.3 Procedural Use and Adherence The project has adopted a graded approach to procedural use and has created a framework for classifying procedures to reflect the potential impacts of work not being conducted to specification. All procedures have been classified using the framework described on Figure 5 below.

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Information Activities usually administrative in nature, that do not involve physical activity or direct contact with plant equipment, are performed frequently and have no Use immediate consequences if performed improperly.

Reference Activities for which the consequences of an improper action are not immediate Use and are not irreversible. Increasing RiskLevels Activities for which the consequences of an improper action could have an Continuous immediate, possibly irreversible adverse impact on Safety, where Safety Use includes nuclear, radiological, industrial, environmental, health and security related safety.

Multi Activities for which sections or subsections designate different levels of use Use (reference and continuous) may be classified as multiple use Varying RiskLevels Figure 5 NNB GenCo (SZC) Procedural Use & Adherence Classifications In addition, procedure adherence expectations for managers and staff have been defined and been included in training provided to all staff.  Responsible Managers are clear which procedures are core to their team’s operation and which their staff should be competent in using.  Responsible Managers ensure this information and the importance of procedure use and adherence is communicated to new staff (permanent and embedded contractors) and reinforced on an ongoing basis.  Staff are walked through / supervised / monitored during their first executions of the procedures to ensure they fully understand the procedure requirements, supporting documents, systems and controls employed.  Responsible Managers communicate changes to procedures, provide training and revalidate competence when required.  Responsible Managers promote the need to raise non-conformances when a procedure is clearly not being followed or the expected business outcome is not achieved, and to raise learning reports if the process is deficient.  All users are expected to propose improvements via the organisational learning system.

3.6.4 Procedure Review Periods To ensure company procedures (and some other specific documents) are regularly reviewed to ensure they meet the needs of the project, a maximum period of 3 years between reviews of procedures is in place. The 3-year review period is monitored by the Management System Governance Group.

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A.1 Appendix A

A1. Process Groups

A1.1. Management Processes The management processes give direction and assurance on the core and support processes. Some management processes support NSL, environmental permits or international standards requirements. The project management processes, their objectives and descriptions are as below.

A1.2. Safety Leadership & Management Process Group Objective: To ensure the safety of the public and workforce through robust safety arrangements and a strong safety culture. (Safety includes nuclear, radiological, industrial, environmental, health and security related safety). Process Group Description & Scope: To identify safety requirements and establish and implement the safety strategies to drive decision making across the organisation. To continually assess and improve safety performance through appropriate leadership. Component Business Processes. Identify Safety Requirements - identify and establish compliance with all safety related legislation and regulatory requirements applicable.  Establish Safety Objectives & Targets - define the Safety objectives for the project and our supply chain. set, communicate, and regularly review Safety targets.  Establish & Implement Safety Strategies - develop strategies to deliver the systems, controls, values and behaviours required to achieve our Safety objectives, regularly reviewing their performance, adjusting to improve their effectiveness and modifying to incorporate changes to legislation and business need.  Assess Safety Performance - review Safety performance, through evaluations, performance reviews, self- assessments, benchmarking, incident investigation and appraisal of external experiences, identifying action plans to improve the robustness and effectiveness of the Safety arrangements; and  Improve Safety Performance - facilitate continuous improvement whilst supporting a healthy safety culture through reporting commendable and non-commendable internal events, and knowledge gained from external events, to allow the promotion of good practice and assist personnel to avoid errors and bad practice.

A1.3. Governance Process Group Objective: To embed an integrated governance framework covering the decision-making, performance management and control of NNB GenCo (SZC); 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 in NNB GenCo (SZC). Process Group Description & Scope: To define and document the policies, processes, procedures, controls, and accountabilities for decision-making within the project, ensuring safety is pre-eminent. To ensure that risks are

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effectively mitigated, and robust controls are established. To provide legal counsel to ensure that NNB GenCo (SZC) complies with all relevant legislation, policies, and procedures. Component Business Processes:  Identify Legal Requirements – to understand the regulatory and legislative requirements and define the standards for the way in which NNB GenCo (SZC) will work.  Define Governance Arrangements – to identify, define, implement, and manage the necessary decision- making processes and delegations of authority; to manage the risk framework defined for the management of risks.  Provide Legal Counsel – to provide personnel responsible for giving advice and guidance on all legal matters affecting NNB GenCo (SZC), and to act in court if required.  Maintain the Integrated Management System – to maintain the NNB GenCo (SZC) integrated management system, which integrates all the organisational processes and procedures into one complete framework and defines the requirements for measurement, assessment and continual improvement of health, safety, environmental, security, quality and financial elements.  Assess Compliance & Performance – to assess compliance and performance of the management system through mechanisms including management review

A1.4. Business Planning & Investment Process Group Objective: To define the mission, ambitions, and values of NNB GenCo (SZC) as well as the strategic objectives aligned to EDF Energy. To provide financial forecasts for the business programme and to monitor performance against the objectives and forecasts. Process Group Description & Scope: To define the strategic objectives and establish the medium- and long-term business plans, financial budgets and forecasts based on the EDF Energy medium term plan. To monitor the performance of NNB GenCo (SZC) against its objectives, budgets, and forecasts and to ensure the availability of financial resources to meet NNB GenCo (SZC) business objectives. Component Business Processes:  Define Mission, Ambitions & Values – to establish the mission, ambitions, and values of NNB GenCo (SZC).  Define Objectives & Performance Framework – to define the objectives of NNB GenCo (SZC) and the framework for assessing the success in achieving those objectives.  Manage Investment Case – to manage the investment case and to continually update and review it because of business performance over time, market forces and external factors.  Prepare Budgets & Forecasts – to prepare the medium-term plan, annual budgets and quarterly forecasts including budget approvals, monitoring and review of budgets and forecast data.  Arrange Funding – to liaise with NNB GenCo (SZC) shareholders and external stakeholders to ensure funding for the project is delivered at the appropriate time and in accordance with budgets.  Monitor Financial Performance – to monitor and control financial data including comparison of actual figures against budgets & forecast and monitoring the efficiency of the hedge strategy.

A1.5. Assurance Process Group Objective: To provide confidence that technical, health & safety, quality, nuclear, environmental and security requirements are complied with.

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Process Group Description & Scope: To perform business, technical and regulatory assurance activities and to oversee non-conformance resolution. Component Business Processes:  Establish Independent Assessment Programme – to establish an integrated schedule of all assurance and compliance assessments, including external audits, self-assessments, and management reviews.  Conduct Assessment – to assess compliance against requirements including Nuclear Site Licence, health, safety, environment, quality, and security through internal or external audits. This can be conducted through documentation reviews, inspections, and surveillance.  Manage Findings - 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  Escalate Findings - To identify and resolve shortfalls in behaviours, culture, compliance, or safety by ensuring that the communication of advice is escalated to the appropriate level of management.

A1.6. Core Processes The core processes are the process capabilities that deliver the key objective. Some core processes support NSL, environmental permits or international standards requirements. The NNB GenCo core processes include:

A1.7. Project Management Process Group Objective: To deliver project scope in a safe manner, ensuring timely and cost-effective delivery to the right level of quality. Process Group Description & Scope: To plan, organise, secure, and manage the resources required to successfully complete the SZC project. Component Business Processes:  Plan Construction - to manage the planning which will inform the order and scope of construction activity throughout the execution of the project.  Conduct Project Initiation - define a project's scope, approach, plan and resources enabling the organisation to understand the work that needs to be done to accomplish the project's deliverables prior to committing resources and/or budget.  Conduct Project Gateway Review - manage the controlled execution of a project, reviewing progress and performance, taking corrective actions. Reviewing preparedness and provide authorisation to move between project phases.  Conduct Project Closure - formal closure of the project, ensuring all deliverables have been handed over, outstanding issues have an accepted business owner, commercial contracts are closed, and the project closure report approved.  Control Project - providing scheduling, cost, risk and change processes and systems to facilitate the controlled execution of the project and the reporting of project performance for management review.  Manage Contract - providing commercial administration of contracts, from their initiation, through their execution, including cost and progress verification, contract change and dispute resolution, through to ultimate and timely contract closure.  Manage Quality - to manage the planning, management, audit, and improvement of Quality throughout the execution of the Project.

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A1.8. Design Process Group Objective: To produce an integrated design that meets the safety and commercial requirements and obligations of NNB GenCo (SZC) as an operator and licensee. Process Group Description & Scope: To manage the interface with the design organisation and the subsequent adaptation of detailed design to meet UK and site-specific requirements, ensuring compliance with regulatory controls and ensuring replication of the HPC design as far as possible. Component Business Processes:  Capture Requirements for Design – To capture requirements from the full spectrum of contributors, validating submissions and where appropriate, accepting the requirement prior to cascading to the appropriate design entities for action. Also controls anticipated technical risks and exploit identified technical opportunities associated with the design, providing a mechanism to assess actions in the context of the holistic design and in an integrated fashion.  Produce Design – to enable the Project to achieve Intelligent Customer control over the production of the design by the relevant designer. As such, the arrangements provide oversight to the work undertaken by the Responsible Designer or Contract Partner, along with instructions and specifications to support the specific UK and Project context. Also ensures proposed changes to the design are documented, reviewed and approved prior to the work being undertaken, then subsequently incorporated into all aspects of the design and issued for execution.  Manage Design Change – to minimise design change from the base design of Hinkley Point C, and where design change is unavoidable, ensure proposed changes are documented, reviewed and approved, and to also ensure that the safety and environment cases are updated throughout the lifecycle of the plant.  Accept Design – to support the formal review and acceptance of project design deliverables, ensuring claims made in the safety case, environmental case, security arrangements and Project business case at each stage of the plant life cycle are fulfilled by the plant as finally installed and commissioned.  Establish Design Readiness - to support internal and regulator controls to ensure the design is in a suitable state to release the dependent activities, whether they relate to detailed design, procurement, manufacture, or construction.

A1.9. Procure Process Group Objective: To procure the goods and services that meet quality, safety and financial requirements for the construction, operation, and decommissioning of the nuclear plants. Process Group Description & Scope: To manage all the activities in support of the procurement of goods and services for the construction of nuclear plants. Component Business Processes:  Develop Procurement Strategy - to select the procurement route to be followed, development of the procurement strategy, establishing the pre-qualification questionnaire and agreeing the associated scoring mechanism.  Pre-Qualify Suppliers – to issue the pre-qualification questionnaire, conducting credit checks, receiving returns, analysing responses and production of an evaluation report which provides a shortlist of suppliers for inclusion in the tender process.

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 Conduct Tendering – to create and issue the tender, evaluation of responses and the approval of contract strategy paper upon which negotiations will be based. Associated processes of supplier assessment and credit assessment are undertaken to ensure suppliers have appropriate organisational arrangements in place to meet contractual requirements prior to contract award.  Negotiate & Select Suppliers– to confirm of contract scope and alignment of parties involved in the negotiations, undertaking the negotiations with supplier/contractor, through to preparing the contract recommendation pack presented for approval prior to contract signature.  Award Contract – to present the contact for investment approval, creation of the purchase requisitions and release of purchase orders within the financial system, together with formal signature and exchange of contract.

A1.10. Manufacture Process Group Objective: To ensure critical components are provided by competent suppliers to meet the technical, performance and quality specification of the design. Process Group Description & Scope: to provide assurance of the correct application of contractual arrangements and the conformity of components and equipment with specified requirements. Component Business Processes:  Assess Supplier Qualification – to qualify the preferred bidder (main Contract Partner with its supply chain) before contract signature and through the contract life, based on an evaluation of technical capabilities and management system assessment.  Conduct Manufacturing Surveillance – to ensure conformity of equipment, parts, and fuel assemblies against contractual requirements, the review of manufacturing documentation, the management of in- shop inspection and the quality release of the equipment and parts before shipment to site.  Issue Quality Release Certificate - to support the Quality release of equipment or parts, following the completion of all the surveillance activities performed by the Licensee, the Responsible Designer and the Conformity Assessment Bodies during the design and manufacturing steps. It enables the shipment of equipment to site and the transfer of lifetime records to the Site Documentation Centre.  Conduct On-Site Fabrication Surveillance - to conduct surveillance during fabrication activities on site, such as equipment assembly, welding, non-destructive testing, and segregation of materials.

A1.11. Construct Process Group Objective: To ensure the activities undertaken at Site are conducted in a safe manner, to the right quality and agreed timescales whilst complying with the requirements (Licence Conditions, Environmental Permits, Planning Conditions, etc.) Process Group Description & Scope: To manage the construction programme and discharge the responsibilities of the ‘Intelligent Customer’ in relation to the construction outsourced to the Contract Partners. Component Business Processes:  Mobilise Contract Partner – to ensure the Project is ready to receive the Contract Partner on Site, including kick-off meetings, logistical arrangements, handovers from previous construction phases and ensuring the Contract Partner has completed their preparations.

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 Manage Construction – to control the construction activities on site, ensuring work is planned and the associated risk assessments/method statements are agreed, Contract Partner activities are coordinated, the quality and safety of the work activities are monitored and any non-conformances are addressed.  Manage Construction Change – to co-ordinate, communicate, accept and implement clarification and change related activities between the various interested parties, including the manufacturer, Contract Partner and the party responsible for the design.  Accept Completed Work – to ensure the handover of work undertaken by the Contract Partner to another Contract Partner and the formal acceptance of work and transfer of ownership to the Site Construction Team on behalf of the licensee.  Demobilise Contract Partner – to manage the orderly exit of the Contract Partner from the Site, including return of equipment and facilities and their removal of materials and construction plant.  Manage Site Operations – to manage the full spectrum of logistical and Site facilities, spanning delivery management, Site access, catering and welfare facilities, through to site communications, roads and office facilities, and the provision of shared site services, such as on-site plant hire and the fuel supplies.

A1.12. Commission Process Group Objective: To confirm the functional and safety performance of the reactors, their supporting systems and the conventional plant installed at the station. 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. Component Business Processes:  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.  Handover to Operations – to compile the test procedures and all related documentation for handover to operations.

A1.13. Operate Process Group Objective: To ensure the safe, reliable, and efficient running of the station. Process Group Description & Scope: All activities required to operate and maintain the plant, ensuring the plant operates safely, reliably, efficiently with optimised performance and scheduled maintenance. Component Business Processes:  Prepare Operational Capability – to prepare for operational running considering experience learned through the construction and commissioning phases.  Operate Plant – to carry out routine operations, plant monitoring, refuelling and return to service following modifications.

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 Maintain Plant – to keep the plant in the required condition including maintenance activities and control of plant spares procurement.  Manage Nuclear Fuel – to handle and store Nuclear Fuel from control of fuel procurement, transport, receipt at the station and the transportation of the irradiated fuel.  Manage Power Purchase Agreement – to own and manage the Power Purchase Agreement which will specify price controls agreed with EDF Group.

A1.14. Decommission Process Group Objective: To plan for the decommissioning of a nuclear plant at the end of a plant’s productive lifecycle in accordance with statutory requirements. Process Group Description & Scope: To manage the preparation of a corporate decommissioning strategy to comply with statutory, regulatory and licensing requirements and ensure that NNB GenCo (SZC) is able to meet the full cost of decommissioning its nuclear plants and meet its share of waste management costs. Component Business Processes:  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.

A1.15. Consents, Permits & Licences Process Group Objective: To satisfy external planning requirements for obtaining development consent orders, and to obtain a nuclear site licence and environmental permits, and to meet statutory requirements during the life of the build. Process Group Description & Scope: To manage the lifecycle of the application from identification of the required consents, permits and licences through to managing changes for consents, permits and licences that have been granted. Component Business Processes: Maintain Consents, Permits & Licences – to obtain the necessary consents, permits and licences including development consent orders, environmental permits, and a nuclear site licence.  Change Consents, Permits & Licences – to ensure that there are appropriate management arrangements in place to identify when changes are required to any of the consents, licences and permits held by NNB GenCo (SZC), and the process by which to apply for any changes identified.  Relinquish Consents, Permits & Licences - to ensure that there are appropriate management arrangements in place to relinquish any of the consents, licences and permits held by NNB GenCo (SZC);  Communicate with Regulators - to ensure communication with regulators is professional, controlled, consistent and appropriately documented. This will help ensure a healthy, open, and transparent relationship with the regulators.

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A1.16. Support Processes The support processes are the process capabilities that enable the core and management processes to function. Some support processes incorporate NSL, environmental permits or international standards requirements. The NNB GenCo (SZC) support processes include:

A1.16.1. Documents & Records Process Group Objective: To deliver and maintain a coherent and co-ordinated approach to Document and Records Management throughout NNB GenCo, to ensure consistency of approach, effectiveness in operations, compliance with regulations, and to meet commercial objectives, whilst protecting information and access to it. Process Group Description & Scope: To manage documents and records produced and received by NNB GenCo (SZC), meeting regulatory requirements for the collaboration of information and the management of nuclear lifetime records. Component Business Processes:  Establish Documents & Records – to manage the production of new documents and records (including the generation of revised versions incorporating changes and the storage of physical records) so that appropriate control is maintained over quality, versions, and authorisation.

 Maintain & Access Documents & Records– to ensure that documents and records are kept up to date and access, particularly to physical records, is properly controlled.

 Dispose of Documents & Records – to ensure that documents and records which are no longer required are appropriately disposed of.

A1.16.2. People Process Group Objective: To recruit, develop and retain competent and motivated people, ensuring that the organisation has the right number of competent people during each stage of the project lifecycle, and that changes in the organisation are managed appropriately. Process Group Description & Scope: To advise and support line management on all aspects of people management as well as potential and actual employees and contractors and to ensure that changes in the organisation are managed appropriately and in accordance with statutory, regulatory and licensing requirements. Component Business Processes:  Plan and Change Organisational Structure and Resources – to prepare resource requirements, succession planning, workforce risk assessment and the design of the organisation in addition 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.

 Recruit, Transfer & Extend Staff – to select, assess and recruit candidates including liaising with third party recruitment consultancies, advertising vacancies, and managing employment contracts.

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 Develop & Manage Workforce Performance – to provide guidance and coaching to line managers to enable them to achieve optimum performance from their people, including guidance on periodic performance reviews as well as support in managing under performance and bespoke team and individual orientated interventions. Maintain oversight of talent within the organisation and ensure processes are in place and utilised to enable effective succession management and individual career development.

 Support People –to provide support to the workforce in managing the requirements of work and personal life and promote and support optimum physical and mental well-being and provide support to the operation of the Human Resources function.

 Manage Leavers – To handle employees leaving the business.

A1.16.3. Training & Qualification Process Group Objective: To ensure that individuals receive the appropriate training to develop the competencies needed to perform their assigned roles. Process Group Description & Scope: Applies to all NNB GenCo staff and contracted and non-plant personnel through the pre-construction, construction, and operating phases. Training, experience, and educational requirements associated with each designated role are established, as well as the process for assessing individuals against these requirements. Appropriate training is identified, produced, and delivered using a systematic approach. Component Business Processes:  Manage Roles & Competencies – 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 those.  Develop Training – to provide the process for enrolling in training at NNB GenCo (SZC).  Deliver Training – to apply the Systematic Approach to Training (SAT) to provide training that enables personnel to perform their jobs effectively and efficiently.

A1.16.4. Communications Process Group Objective: To ensure the NNB GenCo (SZC) strategy, objectives and message is positively received by all stakeholders and to recognise the relationship with EDF Energy for external communication. Process Group Description & Scope: To manage external communications including:  Handle Public Affairs – to manage all aspects of public affairs including strategy, planning, lobbying, stakeholder engagement and communication.  Manage Media Relations – to manage all aspects of media relations including strategy, planning, media enquiries and releases as well as providing support for events and exhibitions.  Manage Governmental Relations – to become acquainted with government officials with the intention of helping them conduct their business of formulating and executing public policy.  Provide Shareholder Communications – to communicate NNB GenCo (SZC) performance forecasts and results including annual and long-term objectives.

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 Deliver Nuclear Education & Showcasing – to provide greater internal and external understanding of the nuclear energy business by building public and customer awareness.  Manage External Stakeholders – to establish a relationship with external stakeholders including members of the public and regulators to understand their requirements and expectations.

A1.16.5. Finance Process Group Objective: To provide financial accounting services and manage the interface with EDF Energy Shared Service teams. Process Group Description & Scope: To provide financial accounting support, to manage the payroll and to prepare periodic reporting to EDF Energy. Component Business Processes:  Process Financial Transactions – to include GL journals, inter-company entries, payables, receivables, fixed assets, cash, bank reconciliation, and month-end processes.  Prepare Financial Reports & Accounts – the preparation of financial accounts and the creation and generation of reports to meet statutory, tax and management reporting requirements.  Support & Maintain Financial Systems – manage the organisation structure, cost/profit centres and hierarchies and manage interfaces to other systems/departments.  Manage Financial Risk – to manage all forms of financial risk including credit and foreign exchange.

A1.16.6. Information Management Process Group Objective: To provide Information Systems (IS) which can provide and manage the information required to effectively manage the organisation. Process Group Description & Scope: The planning, acquisition, implementation, monitoring, evaluation, delivery, and support of the IS services used to manage NNB GenCo information. Component Business Processes:  Plan & Organise IT Services – to plan the use of IT and how best it can be used to help achieve the company’s goals and objectives. It also highlights the organisational and infrastructural form IT is to take in order to achieve the optimal results and to generate the most benefits from the use of it.  Acquire & Implement IT Services – to identify IT requirements, acquire the technology, and implement it to support the company’s business processes. This also addresses the development of a maintenance plan that a company should adopt to prolong the life of an IT system and its components.  Deliver & Support IT Services – to focus on the delivery aspects of the IT. It covers areas such as the execution of the applications within the IT system and its results as well as the support processes that enable the effective and efficient execution of these IT systems.  Monitor & Evaluate IT Services – Ensure IT services meet NNB GenCo business requirements, are compliant with regulatory requirements and deliver to agreed Service Level Agreements (SLA’s) for all IT service delivery elements.  Provide Management Information – to collect, analyse and provide information on the performance of the organisation.

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A1.16.7. Properties & Facilities Process Group Objective: To provide property and facilities services that satisfies the needs of all stakeholders. Process Group Description & Scope: The provision of property and facilities management services at designated NNB GenCo sites. Component Business Processes:  Acquire Property Sites – to acquire and set-up properties including the negotiation of site lease and other contracts / costs.  Maintain Property Sites – to maintain NNB GenCo designated properties including the execution of property related health, safety, security and sustainability requirements.  Dispose of Designated Property Sites – to dispose of properties including the negotiation of site lease termination and other contract costs, removal of site furniture and IT infrastructure.

A2. Definitions

A2.1. Policy A suite of policies exists to ensure all employees operate in a way that meets or exceeds the requirements of our shareholders, key stakeholders, employees and legal requirements. The policies either come from EDF SA, EDF Energy or have been developed to meet specific NNB GenCo (SZC) needs. The NNB GenCo (SZC) Ltd Board has overall authority for policy approval and appointment of the Policy Owner who has accountability for its health and adoption within NNB GenCo (SZC). Policies, by their nature, are mandatory and must be complied with by all employees.

A2.2. Policy Practice & Guidelines One or more Practice & Guidelines may accompany each Policy. They are a combination of define (what) and describe (why and how) categories. The description component elaborates the high-level policy statements by specifying detailed practices employees must do or must avoid doing. The describe component is supporting guidance to help assist in the interpretation of the policy and practices. Compliance with the practice, like the policy itself, is mandatory.

A2.3. Executive Committee Terms of Reference Definition document detailing the purpose, scope, authority, and membership of executive committees. Terms of reference are approved by the Board and are mandatory in terms of the discharging the defined duties and operating within the defined scope only.

A2.4. Process Group and Process Process groups comprise of several processes, which in turn comprise of a number of company procedures. They define, at a high level, the objective and scope of the key activities undertaken by the business, and the interactions with other process groups and external organisations. They are approved by the Board, who also

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appoint the Process Owners who has accountability for its health and adoption within NNB GenCo (SZC). Employees must operate within the defined scope of process groups and processes.

A2.5. Procedures These mandatory definition documents are linked to form interactive chains which make up individual processes. The purpose and scope are clearly defined to ensure their objectives and the boundaries in which they apply are clearly understood. They are broken down into several activities, with associated purpose, sub-steps and responsibilities also clearly defined. Procedures are managed by Process Leads, appointed by the Process Owner, and have accountability for the Procedures health and adoption.

A2.6. Work Instruction These definition documents are also mandatory. They generally cover a single activity, but can cover more than one activity, but cannot cover the responsibilities of more than one team. They help to describe in detail how the activity is to be completed and aim to ensure a consistent outcome, which is achieved either through the content of the work instruction or through reference to an associated standard. A work instruction may also contain elements of description, in the form of guidance, to enable the associated tasks and decisions to be undertaken without error. They are approved by the individual with management responsibility for the activity supported by the work instruction.

A2.7. Business Forums Terms of Reference Definition document detailing the purpose, scope, authority and membership of business forums and groups. Terms of reference are approved by the parent executive committee or in accordance with associated procedure through which they are established. Forums and groups are mandatory in terms of discharging the defined activities and operating within the defined scope only.

A2.8. Specification A definition document detailing an explicit set of requirements to be satisfied. The specification will be agreed by the associated parties, generally customer and supplier, involved in the relationship. It is mandatory and aims to ensure the exchange between the parties, whether a physical product, service, or information exchange, meets expectations.

A2.9. Standard Like a specification, but this definition document is generally generated by one party for use by multiple parties. The standard is mandatory, with the aim of ensuring the output or activity of one party consistently meets the requirement of the other.

A3. Description of Elements

A3.1. Organisational Note An organisational note describes a directorate, department, or team in terms of purpose, scope, structure, activities and measures. The organisational note looks to paint a rich picture to enable the reader to build up a clear understanding of what the organisational unit is about. An organisational note will generally be consumed by

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members of the organisational unit, particularly new starters as part of their induction, or by 3rd parties when a new business relationship is being established, to understand what their new business partner is about. An organisation note will be approved by the responsible manager and is for information only.

A3.2. Manual A manual is a how to guide established by an organisational unit to enable associated staff to put the tasks they are expected to undertake into context, understand when they are to undertake them and how they are to undertake them. It will place several definition documents, such as company procedures, specifications and standards into context, and explain how they are to be used or undertaken. The explanation may be through the document itself or through work instructions. The manual must not define new processes or company procedures, which must be detailed in framework (overview), or define (what) components of the IMS.

A3.3. Briefing A description document aimed at increasing awareness and understanding of the reader. Not instructive in any way, a brief will explain what needs to be done and point to where additional information, guidance and instruction can be found.

A3.4. Guide A guide aims to explain to non-experts and 3rd parties what they need to do and how they need to do it in relation to one or more definition documents. A guide prevents the individual having to delve into the detail of a definition document to undertake the task. Not mandatory, they may well support mandatory activities defined elsewhere.

A4. Ownership

A4.1. Process Owner The process owner is the person who is accountable for all aspects of a business process. For developing it, implementing it and making sure that it works well. The process owner is accountable for how well a process performs and maintains quality and control of the process. Process owners are assigned by the NNB GenCo (SZC) Board at the process group level of the process hierarchy and are accountable for all the processes and procedures that sit within the process group. Key accountabilities of process owner are to:  Understand and articulate the scope and purpose of the process group and to communicate this to the business and other stakeholders.  Ensure the process group is aligned with the NNB GenCo (SZC) mission, ambition, values and strategic objectives.  Ensure appropriate resource is in place to develop, implement, monitor and manage the underlying processes in line with the process governance framework.  Ensure the processes meet the evolving business requirements and actively promote process improvement; and  Assess the performance of the process group by carrying out process self-assessments.

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A4.2. Process Lead A process lead is the person who will manage the development, implementation, and day to day operation of a business process. The process lead is assigned by the process owner and will generally be one of their direct reports. Key accountabilities of process lead are:  Nominating an author and reviewer and deciding which stakeholders should be consulted when developing company procedures.  Agreeing the process implementation plans, tracking progress and conducting a post implementation review.  Ensuring the company procedure is complied with and non-conformance and learning reports addressed.  Keeping the process owner informed of process performance including escalating any process issues; and  Assess the performance of the process through a process of self-assessment.

A4.3. Policy Owner A Policy Owner is the person who is accountable for the development and implementation of the policy through business activity. Key responsibilities of the policy owner are:  Appointing the policy lead.  Providing guidance to the policy lead on policy requirements  The development of the policy in line with the framework  Assessing the impact of the policy on the business  The development of the communication plan and confirming it has been completed.

A4.4. Policy Lead A policy lead is the person who will manage the day to day implementation of the policy to ensure the policy is met through business activity. Policy leads are appointed by policy owners. Key responsibilities of the policy lead are:  Review EDF Energy policy proposals.  Assess the impact of EDF Energy Policies on NNB GenCo (SZC)  Develop NNB GenCo policies and consult with the NNB GenCo (SZC) Policy Owner through the policy lifecycle  Assess the impact of NNB GenCo (SZC) policies on the NNB GenCo (SZC) business.  Agree actions and tracking for implementation  Communicate the policy to the business

A4.5. Legislation Category Owner The responsibilities of legislation category owners are complimentary to the responsibilities of process owners with regards to ensuring processes meet evolving business requirements. A legislation category owner is responsible for ensuring the legislation items within an assigned category (e.g. environmental, property & facilities, etc) are met through the business activity. A legislation category owner may appoint legislation category leads to support the delivery of their responsibilities on a day-to-day basis.

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A4.6. Legislation Category Lead A legislation category lead is the person who will ensure the business activity meets specific legislation and regulatory requirements on a day to day basis through process development, implementation, and assessment. Legislation category leads are appointed by the legislation category owner. Key responsibilities are to:  Review new or amended legislation and regulatory requirements to identify whether they apply to NNB GenCo (SZC) and update the relevant Applicability Register.  Identify the implications and establish the arrangements, actions and training needs required to achieve compliance with the legislation or regulatory requirements.  Implement identified actions to ensure NNB GenCo (SZC) has arrangements in place to achieve and maintain compliance with applicable legislation and regulatory requirements. Systematically review existing legislation, regulatory requirements, and Applicability Registers, evaluate any ongoing impacts.

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Nuclear Safety Policy Sizewell C

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Nuclear Safety Policy

POLICY STATEMENT NNB GenCo (SZC) is leading the way in building a fleet of safe, reliable nuclear power stations without costing the earth. Nuclear safety requires us to protect individuals, society and the environment by establishing effective defences against radiological hazard throughout the project and future plant operation and decommissioning. Nuclear safety is our overriding priority. Every one of us has a direct or indirect impact on nuclear safety and it must be in the forefront of what we do. The commitments in the EDF Group Nuclear Safety Policy (Ref. 1) are enacted in our arrangements. NNB GenCo (SZC) has a special responsibility to deliver new nuclear power safely as part of the UK energy policy. Success requires that we demonstrate and maintain the highest standards of safety, quality and efficiency. These standards will be applied throughout the design, procurement, manufacture, construction, commissioning and operation of our plants and through to their eventual decommissioning. We adopt the following definition of Nuclear Safety Culture (Ref. 2): That assembly of characteristics and attitudes in organisations and individuals which establishes that, as an overriding priority, nuclear plant safety issues receive the attention warranted by their significance. We recognise that excellence is underpinned by human performance and our culture will be based on leadership, integrity, openness, teamwork, and challenge. We will follow procedures, demonstrate a questioning attitude, uphold the highest standards whilst always looking for opportunities to learn and improve. In addition, we recognise the guiding principles issued by the Institute of Nuclear Power Operations (INPO) (Ref. 3) and the World Association of Nuclear Operators (WANO) (Ref. 4). We ensure that our arrangements support radiological, environmental, industrial and fire safety effectively in support of our ambition to achieve a Zero Harm safety record. This policy requires the commitment of all leaders and staff to support and demonstrate the values outlined in this policy and the commitment of all individuals to maintain positive control of nuclear safety via deliberate, considered actions.

Humphrey Cadoux-Hudson, Managing Director For and on behalf of the SZC Executive Team

Policy Owner: Safety, Licencing and Assurance Director SZC

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Nuclear Safety Policy

SCOPE OF THIS POLICY This policy will be applied in a proportionate manner to all activities that have the potential to impact nuclear safety either now or in the future. It will guide the way we work and the decisions we make in designing, procuring, manufacturing, constructing, commissioning, operating and ultimately decommissioning our plant. This requirement extends to everyone who works on the project regardless of whether they are part of the NNB GenCo (SZC) organisation, provide support from the wider EDF organisation or contribute to the project as a supplier of plant or services. Implementation of this policy will be through the Integrated Management System and governance arrangements supported by development of a strong nuclear safety culture. PEOPLE & ACCOUNTABILITY The NNB GenCo (SZC) Board has ultimate accountability for nuclear safety through the strategies and policies that it sets and decisions it makes. NNB GenCo (SZC) Executive Directors have overall responsibility for establishing and maintaining arrangements to manage nuclear safety and to ensure the effectiveness of these arrangements are kept under review. All Leaders are responsible for overseeing the actions needed to implement these arrangements and support continuous improvement in Nuclear Safety standards. All staff and contractors have a personal responsibility for nuclear safety and ensuring that nuclear safety is our overriding priority through their individual actions.

NNB Generation Company (SZC) Limited Registered in England and Wales. Registered No. 09284825 Registered Office: 90 Whitfield Street, London, W1T 4EZ

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Nuclear Safety Policy

POLICY STANDARDS

LEADERSHIP 1. Everyone is responsible for nuclear safety and it is an inherent part of all that we do. Leaders in NNB GenCo (SZC) and across the supply chain demonstrate a commitment to nuclear safety with strong front line supervision a key part of success. They recognise that the special requirements of nuclear construction and subsequent nuclear operation demand strong and informed leadership, a visible presence and conservative decision making.

NUCLEAR SAFETY CULTURE 2. We achieve construction excellence and safe future operation through continually fostering a strong nuclear safety culture. We expect a safety conscious work environment. Our nuclear safety culture is characterised by effective communication, openness, mutual trust and shared values which place nuclear safety as our overriding priority. We follow our approved procedures, demonstrate a questioning attitude and uphold the highest standards. We seek to learn and act to improve. PEOPLE 3. People recognise that nuclear construction excellence has special requirements that endure throughout the lifecycle. They understand their nuclear safety responsibilities and that each individual may have an impact on nuclear safety. All staff are qualified to do their jobs, possess the skills to perform their duties to the required standards and employ error prevention techniques in day to day activities. PLANT AND EQUIPMENT 4. We understand the nuclear safety significance of our plant and equipment. Plant is designed to ensure that the risks from nuclear operations are as low as reasonably practicable. The plant is built as designed and will be commissioned, operated and maintained within established safety cases and safety standards. PROCESSES 5. Strong processes are part of the multiple barriers to support nuclear safety. Processes are robust, proportionate and focused on maintaining positive control of all our activities. All work is planned to ensure that safety and quality are achievable at all times and that our resources are effectively used. We are prepared to respond to incidents and emergencies. PERIODIC ASSESSMENT 6. Our nuclear safety performance and culture undergoes constant challenge and is periodically assessed to ensure that the objectives of this policy and the principles listed above are being achieved. LEARNING ORGANISATION 7. We learn from our own and others’ experience and we continually strive for excellence through continuous improvement. We use this learning to inform our decision making.

NNB Generation Company (SZC) Limited Registered in England and Wales. Registered No. 09284825 Registered Office: 90 Whitfield Street, London, W1T 4EZ

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Nuclear Safety Policy

REFERENCES

Ref Title Location Document No. http://businesses.edf.com/generation edf_group_nuclear_safety_ 1 EDF Group Nuclear Safety Policy /nuclear-power/our-strategy- policy_20012012 43766.html IAEA Safety Culture Safety Safety Series No.75-INSAG- 2 www.iaea.org Report 4 INPO Principles for Excellence in http://www.inpo.org/library/inpodocs 3 INPO 09-007 Nuclear Project Construction /2009/09-007/09-007.pdf WANO Principles for a Strong http://www.wano.org/GoodPractices/ 4 WANO GL 2006-02 Nuclear Safety Culture Guidelines/2006/GL_2006_02_en.pdf

DEFINITIONS

Term/Abbreviation Definition IAEA International Atomic Energy Agency

INPO Institute of Nuclear Power Operations

INSAG International Nuclear Safety Advisory Group NNB GenCo NNB Generation Company Limited WANO World Association of Nuclear Operators

NNB Generation Company (SZC) Limited Registered in England and Wales. Registered No. 09284825 Registered Office: 90 Whitfield Street, London, W1T 4EZ

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Environmental Policy Sizewell C

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Environmental Policy

POLICY STATEMENT

NNB GenCo (SZC) Environmental Policy sets out our approach to achieve the EDF Energy Better Plan including our goal of leading the decarbonisation of the UK electricity sector whilst seeking to achieve a net zero environmental impact across our operations to protect a cleaner, healthier and more resilient environment that benefits society and our economy. Our goal by 2030 is to demonstrate real progress towards reducing our carbon emissions, waste, water use and impact on biodiversity towards net zero. We will also implement circular economy principles into the way we work, pro-actively preventing waste and pollution, achieving greater resource value and productivity. This means we will maintain our position as the UK’s largest low-carbon electricity generator and seek to bring the carbon intensity from our electricity generation to below 50g/kWh by the end of 2030. All employees and contract partners working with NNB GenCo (SZC) share a responsibility for zero harm to themselves and the environment, and strive to deliver continual improvements. NNB GenCo (SZC) will, as a minimum, comply with all relevant environmental legislations, permits and other requirements whilst striving to achieve best performance in our sector.

 We will lead by example by championing innovation and R&D in electric heating and transport in our operations.  We will actively monitor our performance and seek opportunities to improve by setting challenging objectives and targets for ourselves and our supply chain partners.  We will prevent incidents by ensuring our facilities are well designed, safely operated, inspected and maintained.  We will seek to minimise the environmental direct impacts of our business and that of our suppliers and the goods/services we provide to customers by developing innovative solutions to drive best practice and that enable us to deliver the net zero environmental impact goal.  We will work with interested parties to ensure their and our environmental concerns and expectations are considered as part of a robust and transparent decision-making process.

NNB GenCo (SZC) Environment Policy is aligned to EDF Group requirements and is assured through the BEST (Building Excellence in Safety Together) framework assessment. The implementation of this Policy will be through line management. All employees and contractors are expected to work in a manner that helps us to meet our environmental targets. The NNB GenCo (SZC) Leadership Team are confident that by working together and following these key principles we can achieve the goals set out in the Better Plan and the journey towards net zero environmental impact.

Humphrey Cadoux-Hudson, Managing Director For and on behalf of the SZC Executive Team

Policy Owner: Safety Licencing and Assurance Director

NNB Generation Company (SZC) Limited Registered in England and Wales. Registered No. 09284825 Registered Office: 90 Whitfield Street, London, W1T 4EZ

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Health and Safety Policy Sizewell C

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Health and Safety Policy

POLICY STATEMENT

EDF Energy believes all harm is preventable, so our aim is Zero Harm. We have signed the Safety Representative Charter with the Trade Unions to recognise the importance of effective consultation and engagement with employees to achieve zero harm. All staff are responsible for enacting this policy, making health, safety and wellbeing our priority. We expect everyone to act professionally and apply the key principles:

 Every job will be done safely, no matter how important or urgent it is.

 Each of us has a personal responsibility for our own health, safety and wellbeing and for those around us.

 Putting people to work carries a specific responsibility and accountability for health, safety and wellbeing which will be visibly demonstrated.

 Every asset shall be operated safely, minimising the risk to as low as reasonably practicable by applying the principles of process safety.

 Each near miss we learn from reduces the chance of harm next time and we will pay special attention to High Potential Events.

 Each of us will spot, report and deal with hazards to help create a harm free workplace. The Company will provide health and safety training for employees to enable them to meet the required standards of performance. EDF Energy recognises that accidents and ill health may result from failings in management control and are not necessarily the fault of an individual employee. All employees and contractors are expected to accept their responsibility to work safely, adhering to rules and work procedures, using the equipment provided, and generally to contribute to the maintenance of safe and healthy conditions. We will be guided in our activities by our Simple Actions and Life-Saving Rules. Implementation of this policy will be through line management who are responsible for reducing the risks arising from our operations to as low as reasonably practicable, making proper provision for the health, safety and wellbeing of employees, visitors, contractors and those in the community who may be affected by our activities. We will share best practice across the company and externally. EDF Energy’s Health, Safety and Wellbeing Policy is aligned to EDF Group requirements and is assured through the BEST (Building Excellence in Safety Together) framework assessment. We believe that the health and wellbeing of our employees is vital for our company. Each of us carries a responsibility to protect the wellbeing of those impacted by our decisions and behaviours and each of us should be able to feel included at work. Occupational Health offers further support.

We are committed to effective communication on health, safety and wellbeing matters with all relevant parties and will report internally and publicly on our progress.

Humphrey Cadoux-Hudson, Managing Director For and on behalf of the SZC Executive Team

Policy Owner: Safety, Licencing and Assurance Director SZC

NNB Generation Company (SZC) Limited Registered in England and Wales. Registered No. 09284825 Registered Office: 90 Whitfield Street, London, W1T 4EZ

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Security Policy Sizewell C

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Security Policy

POLICY STATEMENT The purpose of this policy is to describe the arrangements for security at NNB GenCo (SZC). NNB GenCo (SZC) is committed to protecting the security of its People (including customers, the public, stakeholders and staff), Information, Systems, Business Relations and Physical Assets.

Each Organisational Unit (Business Unit or other Executive Function) has varying legal, regulatory and operational security obligations due to the different nature of their activities. This policy provides the minimum requirements that are to be implemented company wide.

The key aims of the policy are that each Organisational Unit:

1. Identifies security threats to People, Information, Systems, Business Relations and Physical Assets, the responsibility for implementing them in each Organisational Unit lies with individual Executive Team members. 2. Ensures appropriate security arrangements, processes and contingencies are in place that effectively and economically mitigates the risks associated from identified security threats. 3. Meets all legislative and regulatory security requirements. 4. Meets the expectations of all key security related stakeholders including EDF Group, UK Government and regulators. 5. Documents the requirement for the Executive Team to appoint an Executive Member as the Chair of the Security Forum responsible for Company Security in its entirety.

Humphrey Cadoux-Hudson, Managing Director For and on behalf of the SZC Executive Team

Policy Owner: Safety, Licencing and Assurance Director SZC

NNB Generation Company (SZC) Limited Registered in England and Wales. Registered No. 09284825 Registered Office: 90 Whitfield Street, London, W1T 4EZ

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Security Policy

POLICY STANDARDS

1. NNB GenCo (SZC) will participate with EDF Energy, and maintain an appropriate security framework, assured by the EDF Energy Security Forum (ESF) and the Security Development Group (SDG). Security arrangements, procedures, governance, contingencies and guidance material are applied across NNB GenCo (SZC) and EDF Energy to ensure a consistent company-wide approach to security. 2. Security arrangements in regulated businesses and in those that directly support regulated businesses are in place to ensure that the requirements of Licensee Boards and Regulators are met. 3. Roles and responsibilities for the implementation and maintenance of security are clearly defined and communicated at company level and within each Business Unit/ CSF. 4. Education and training programmes are provided to relevant employees to ensure that there is an appropriate awareness of security roles, responsibilities and accountabilities. All employees and contractors on or visitors to our sites are made aware of security arrangements. 5. Each Business Unit/ CSF ensures that key risks to security in their area of responsibility, including risks identified in standard 11 are regularly identified, assessed and managed as appropriate and practical. Security risk assessments are undertaken by people with relevant knowledge and experience, are regularly reviewed commensurate with the threats by the ET via the EDF Energy Security Forum, and take account of any significant changes in circumstances. 6. Security systems are fit for purpose, developed to relevant company, legal and regulatory requirements. Security systems and arrangements are tested in a manner and with a frequency commensurate with the identified level of threat, or as required by legislation or regulation, and are refined to take account of learning and feedback. 7. Each Business Unit identifies, classifies and protects its information in accordance with company, legal and regulatory requirements and regulatory requirements. 8. Arrangements are in place to ensure that our suppliers meet our required relevant security standards. 9. NNB GenCo (SZC) has arrangements in place to protect its people both in the workplace and on business travel (including families for international assignments) which are deployed in each Business Unit/CSF. 10. Each site has an appointed security manager, site security plan, security emergency plan and operational response plan that is appropriate practical and regularly reviewed. 11. NNB GenCo (SZC) will participate with EDF Energy, via EDF Energy Security Forum (ESF) annually reviews and approves EDF Energy’s security arrangements and maintains oversight of Cyber Security. The management of cyber security is assessed through the IT policy. Governance arrangements are in place within each Business Unit /CSF to appropriately review and provide oversight of security arrangements. REFERENCES 1. Nuclear Installations Act 1965 2. Nuclear Industries Security Regulations 2003 (NISR 03) 3. Ofgem Licence Conditions 4. NNB GenCo (SZC) Travel Policy 5. EDF Group Security of Assets against Malicious Acts Policy

NNB Generation Company (SZC) Limited Registered in England and Wales. Registered No. 09284825 Registered Office: 90 Whitfield Street, London, W1T 4EZ

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Intelligent Customer Policy Sizewell C

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Intelligent Customer Policy

POLICY STATEMENT NNB GenCo (SZC) is committed to conducting business pursuant to the highest levels of safety (Nuclear Environmental and Industrial) complying with all relevant legal requirements. This requires NNB GenCo (SZC) to exercise effective control over all aspects of safety of its operations, including the prevention of latent risks that could be inadvertently incorporated into the design of plant not yet built.

The purpose of this Policy is to ensure that NNB GenCo (SZC) maintains control of all activities undertaken on its behalf and is an Intelligent Customer throughout all phases of the work, including the initial decision to contract (the “Make or Buy” decision), setting the standards and selecting a competent contractor, oversight of implementation and acceptance of the work. An Intelligent Customer is defined by the Office for Nuclear Regulation (ONR) as follows: “As an Intelligent Customer, in the context of nuclear safety, the management of the facility should know what is required, should fully understand the need for a contractor’s services, should specify requirements, should supervise the work and should technically review the output before, during and after implementation. The concept of Intelligent Customer relates to the attributes of an organisation rather than the capabilities of individual post holders.”

The Environment Agency (EA) has equivalent requirements as follows: “…Organisations should have the capability to secure and maintain proper protection of people and the environment.”

NNB GenCo (SZC) has established a Nuclear Baseline, and will maintain, an adequate and effective Intelligent Customer capability to ensure that it is at all times in control of activities carried out on its behalf. When choosing between sourcing plant or services in-house or from contractors, NNB GenCo (SZC) will ensure that it has adequate and sufficient in-house capability to be in control over activities that may impact nuclear safety. This consideration will include both the short and long term impact of the decision.

In sourcing plant or services from contractors, NNB GenCo (SZC) will implement arrangements to ensure that it is at all times in control of the work done on its behalf. This includes work subcontracted all the way down the supply chain. Work will only be contracted to organisations with the requisite skills and capacity to carry out the work to the required standards, and oversight of work by NNB GenCo (SZC) will ensure the quality achieved in practice.

The principles of this Policy are enacted by activities and provisions embedded in the NNB GenCo (SZC) Integrated Management System (IMS). The Company Manual [1] describes how NNB GenCo will manage and operate in accordance with a Nuclear Site Licence, the Environmental Permits, and is structured and organised to enable delivery of its obligation to function as an Intelligent Customer.

Humphrey Cadoux-Hudson, Managing Director For and on behalf of the SZC Executive Team Policy Owner: Safety, Licencing and Assurance Director SZC

NNB Generation Company (SZC) Limited Registered in England and Wales. Registered No. 09284825 Registered Office: 90 Whitfield Street, London, W1T 4EZ

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Intelligent Customer Policy

SCOPE

This Policy applies to any NNB GenCo staff or embedded contractor involved in activities to obtain plant or services from a contractor throughout all phases of work, including the decision to contract, setting the standards and selecting a competent contractor, oversight of implementation and final acceptance of the work. This policy applies to obtaining plant, technical work, and goods and services that has the potential to impact nuclear safety, throughout the entire project lifecycle. This policy applies until further notice.

The Policy Standards in Section 4 of this Policy will be reflected in all NNB GenCo contracts and arrangements and therefore this Policy applies to all contractors and the associated nuclear safety related activities, regardless of whether the contract is performed on an NNB GenCo location or off any such location.

In addition, this Policy may be applied on a discretionary basis to contracts not involving nuclear safety in a manner proportionate to the business risk involved. PEOPLE AND ACCOUNTABILITY Anyone engaged on activities within the scope of this Policy is accountable for its implementation consistent with the Policy Standards below. Nonetheless, this Policy provides a clear line of accountability and responsibility from the NNB GenCo (SZC) Board, through key executives, to individual contributors.

The NNB GenCo (SZC) Board is ultimately responsible for the governance of the Company, and therefore ultimately accountable for satisfying NNB GenCo (SZC)’s requirements to be an Intelligent Customer in exercising control over work done on its behalf. The NNB GenCo (SZC) Board has delegated authority for management of the business to the MD and the Executive Team.

The Executive Directors have overall responsibility for establishing and maintaining the NNB GenCo (SZC)’s Intelligent Customer capability and undertaking periodic reviews of effectiveness of the arrangements and to ensure that the Intelligent Customer capability responds to the changing needs of the company throughout the entire project lifecycle.

The Safety Director has a responsibility to establish and maintain independent oversight to assure that all other parts of NNB GenCo (SZC) are functioning as an Intelligent Customer, and periodically to advise the Board.

The Heads of Function have the responsibility to implement the arrangements and deploy an appropriate Intelligent Customer capability through management of their respective functions. Staff and embedded contractors identified on the Nuclear Baseline as having an Intelligent Customer role have the responsibility to work to the arrangements and fulfil their part of the Intelligent Customer role.

POLICY STANDARDS 1. NNB GenCo (SZC) shall retain overall responsibility for, and control of, the nuclear safety of all of its business, including work carried out on its behalf by contractors.

NNB Generation Company (SZC) Limited Registered in England and Wales. Registered No. 09284825 Registered Office: 90 Whitfield Street, London, W1T 4EZ

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Intelligent Customer Policy

2. NNB GenCo (SZC) shall choose between sourcing work in-house or from contractors in accordance with the standards in this Policy, and its implementing procedures, which takes due account of the nuclear safety implications of those choices.

3. NNB GenCo (SZC) shall maintain an Intelligent Customer capability for all work carried out on its behalf by contractors that may impact upon nuclear safety and shall ensure that the control of work is proportionate to nuclear safety risk.

4. NNB GenCo (SZC) shall ensure that it only lets contracts for work with nuclear safety significance to contractors with suitable competence, safety standards and resources, including work sub-contracted all the way down the supply chain.

5. NNB GenCo (SZC) shall ensure that all contractor organisations and their staff engaged on work are familiar with the nuclear safety implications of their activities and interact in a well-coordinated manner with its own staff.

6. NNB GenCo (SZC) shall ensure that contractors’ work is carried out to the required level of safety and quality in practice.

7. NNB GenCo (SZC) may apply these same Policy Standards on a discretionary basis in its contracting that does not involve activities significant to nuclear safety, in a manner proportionate to the business risk involved in the contract

8. Implementation of Policy Standards shall be through activities embedded within the NNB GenCo (SZC) IMS.

REFERENCES 1 NNB GenCo (SZC) Company Manual EDRMS Ref: 100200192

NNB Generation Company (SZC) Limited Registered in England and Wales. Registered No. 09284825 Registered Office: 90 Whitfield Street, London, W1T 4EZ

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Quality Policy Sizewell C

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Quality Policy

POLICY STATEMENT NNB GenCo (SZC) is part of the UK's nuclear renaissance with the construction of a new nuclear power station at Sizewell C.

Quality management is at the heart of successful delivery of our new nuclear programme and our commercial success. We shall meet the requirements of our customers, stakeholders and regulators delivering our business objectives with nuclear safety as our overriding priority.

We will ensure our staff are competent, take responsibility for the quality of their own activities and comply with processes and procedures. They will apply the principles of nuclear professionalism to prevent errors and shall learn from experience using our organisational learning and corrective action processes.

We have established, implemented and will continue to develop our Integrated Management System based on requirements from legislation, international standards, best practice and the expectations of our key customers, stakeholders and regulators. We are committed to achieving construction excellence in all of our activities to ensure the safe, quality delivery of the project and future safe plant operation.

The achievement of this policy is measured by the implementation of objectives supported by quality key performance indicators.

Our quality arrangements ensure:

 We provide the necessary resources, training, working environment and systems to carry out our activities.  Objectives and targets are set, reviewed and measured.  Our suppliers and contractors adopt the highest standards, recognising their contribution to the success of our business.  We seek continuous improvement in the effectiveness of our organisation.

The objectives of this policy can only be achieved by the commitment of all members of the Sizewell C Project together with contractors and suppliers seeking the highest standards of quality to ensure we get it right first time.

This policy applies to all personnel, contractors and suppliers at all sites owned by NNB GenCo (SZC) Ltd. It will guide the way we work and the decisions we make in design, procurement, manufacturing, construction, commissioning, operation and ultimately decommissioning of our plant.

Humphrey Cadoux-Hudson, Managing Director For and on behalf of the SZC Executive Team

Policy Owner: Safety, Licencing and Assurance Director SZC

NNB Generation Company (SZC) Limited Registered in England and Wales. Registered No. 09284825 Registered Office: 90 Whitfield Street, London, W1T 4EZ

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Quality Policy

POLICY STANDARDS The NNB GenCo (SZC) Ltd Board of Directors sets the aims, strategy and policies of SZC Project and monitors performance.

The Executive team ensures assurance arrangements are in place to achieve high levels of quality, efficiency and effectiveness within the SZC Project.

The Safety Director of NNB GenCo (SZC) is the SZC Quality Policy Owner and is responsible for the development of policies and standards for SESHQ compliance and providing independent advice to the NNB GenCo SZC Board, and arranging for the Policy’s maintenance and periodic review, and overseeing the development and implementation of the quality management arrangements within the SZC Project.

All SZC personnel, contractors and suppliers are responsible for the quality of their work, ensuring that the principles and standards detailed in this policy are established, adhered to and continuously improved. In particular;  A Management System will be established, implemented and maintained that meets legal requirements and relevant international standards.  Roles, responsibilities and authorities are clearly defined and communicated to all staff by their leaders.  Line managers ensure that staff are competent to carry out their roles.  All activities are carried out in a safe, efficient and controlled manner, in accordance with approved arrangements/procedures.  A graded approach to control of quality will be applied based on the nuclear safety significance of any activity.  We ensure the highest standards of quality and professionalism are achieved by our suppliers and we monitor and ensure the quality of their products.  Everyone has a responsibility to identify, report and resolve adverse conditions that could impact on the safety and quality of our activities.  A culture of continuous improvement is fostered that supports learning from our own experience and from that of others.  Regular reviews of our management arrangements will be undertaken to support the safety, quality and effectiveness of our operations.

NNB Generation Company (SZC) Limited Registered in England and Wales. Registered No. 09284825 Registered Office: 90 Whitfield Street, London, W1T 4EZ

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NUCLEAR SAFETY COMMITTEE TERMS OF REFERENCE Sizewell C

NUCLEAR CONSTRUCTION EXCELLENCE Safety and quality in a zero harm environment

Document Reference:100197655 Rev 001 NOT PROTECTIVELY MARKED NOT PROTECTIVELY MARKED Sizewell C Nuclear Safety Committee Terms of Reference

Please note: throughout this document, emboldened text indicates clauses which are now active; text which is not emboldened is not yet active.

INTRODUCTION 1.1. The Sizewell C (SZC) Nuclear Safety Committee (NSC) is an advisory body which will, following licensing of the Sizewell C site, provide nuclear safety advice to the Board of the Sizewell C Nuclear Site Licensee, NNB Generation Company (SZC) Ltd, to support its responsibilities for the Sizewell C project. This Terms of Reference document defines how this Committee operates. PURPOSE 2.1. Under the Sizewell C Nuclear Site Licence, a NSC is required (Nuclear Site Licence Condition 13) to advise NNB GenCo (SZC) on a range of nuclear safety and radiological matters. 2.2. The NSC shall consider and provide advice on:  All matters required by or under the Nuclear Site Licence Conditions to be referred to a NSC.  Such arrangements or documents required by the Nuclear Site Licence Conditions as the Office for Nuclear Regulation (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 ONR may specify.  Any other matter which NNB GenCo (SZC) considers should be referred to a NSC. 2.3. Except for Urgent Safety Proposals (see section 9.5 below); the NSC shall consider or advise only during the course of a properly constituted meeting of the Committee. MEMBERSHIP 3.1. NNB GenCo (SZC) shall appoint at least seven persons as members of a NSC, including one or more members who are independent of NNB GenCo (SZC)’s operations. 3.2. The qualifications, current posts held and previous relevant experience of the members of the NSC, taken as a whole, shall be such as to enable it as a Committee to consider any nuclear safety matter likely to be referred to it and to advise NNB GenCo (SZC) authoritatively and, so far as is practicable, independently. 3.3. The name, qualifications, particulars of current posts held at appointment and previous relevant experience of the members of the NSC shall be sent to the ONR forthwith after making such an appointment. Where the ONR notifies NNB GenCo (SZC) that it does not agree to an appointment, NNB GenCo (SZC) shall discontinue the membership. MEMBERSHIP PRINCIPLES 4.1. A quorum of at least five members, including at least one independent member, shall be present at each meeting. Audio or video communications may be utilised to secure a fully quorate meeting. 4.2. Committee members shall be suitably qualified and experienced to consider and advise on a broad range of matters affecting nuclear and radiological safety. FREQUENCY OF MEETINGS 5.1. NSC meetings shall be organised in line with the requirements of NNB GenCo (SZC).

NNB Generation Company (SZC) Ltd. Registered in England and Wales. Registered No. 9284825. Registered Office: 90 Whitfield Street, London, W1T 4EZ.

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AUTHORITY 6.1. The NSC is an advisory Committee to the NNB GenCo (SZC) Board and has no executive function within the organisation. 6.2. These Terms of Reference shall be submitted to ONR for approval and the NSC shall not meet under these Terms of Reference without the aforesaid approval. 6.3. Once approved, no alteration or amendment shall be made to these Terms of Reference unless ONR has approved such alteration or amendment. RESPONSIBILITIES 7.1. The NSC considers and provides authoritative advice as required to the NNB GenCo (SZC) Board on all matters across NNB GenCo (SZC) which may affect nuclear safety or radiological matters on or off the nuclear licensed site. ROLES 8.1. The NSC Chairman identifies individuals suitable to be members of the NSC, agrees the appropriateness of items presented to the Committee, ensures the proper and effective running of the meetings, and approves the NSC minutes. 8.2. NSC members review the matters submitted to the Committee and provide any points for consideration or advice to NNB GenCo (SZC) Board, as appropriate. 8.3. Submission Owners prepare and present submissions to the NSC in a timely manner and consider appropriate responses to any advice, points for consideration or actions raised by the Committee. 8.4. The NSC Secretariat supports the effective running of the NSC. COMMITTEE PROCESSES 9.1. Any document or category of documents considered at a NSC meeting that ONR may specify shall be furnished to the ONR. 9.2. Within 14 calendar days of any meeting of this Committee, and following review by the Chair of the meeting or the Deputy Chair, a full and accurate record of all matters discussed at the meeting including, in particular, any advice provided to the NNB GenCo (SZC) Board, shall be sent to ONR. 9.3. NNB GenCo (SZC) shall notify ONR as soon as practicable if it is intended to reject, in whole or in part, any advice given by the NSC together with the reasons for rejecting such advice. 9.4. The Nuclear Safety Committee shall be informed at the next available opportunity of the intention and rationale for rejection, in whole or in part, of any advice given by the NSC. 9.5. Appendix A details the process for Urgent Safety Proposals to comply with Licence Condition 13 (11). RECORDS RETENTION 10.1. All items presented to NSC meetings and records of all matters discussed at the meetings shall be stored on the Electronic Document and Records Management System as permanent company records. 10.2. The NSC Secretariat is responsible for maintaining these records in accordance with the NNB GenCo (SZC) Document Retention Policy.

NNB Generation Company (SZC) Ltd. Registered in England and Wales. Registered No. 9284825. Registered Office: 90 Whitfield Street, London, W1T 4EZ.

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DOCUMENT CONTROL Version Date Author Comments New document. Based on HPC NSC Terms of Reference, 001 June 2019 Martin Black NNB-102-TOR-000055 v1.0.

NNB Generation Company (SZC) Ltd. Registered in England and Wales. Registered No. 9284825. Registered Office: 90 Whitfield Street, London, W1T 4EZ.

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APPENDIX A - URGENT SAFETY PROPOSALS

A.1. If it is not practicable, because of the urgency of a nuclear safety proposal, to seek the Nuclear Safety Committee’s advice at the next planned and normally constituted meeting, then NNB GenCo (SZC) may seek advice through the NSC “Urgent Safety Proposals” process. These arrangements shall only be used where there is an urgent nuclear safety proposal requiring consideration by the Committee, or critical project matter where the Committee’s advice is deemed necessary to secure nuclear safety or underpin quality within pressing project schedule constraints. A.2. These arrangements shall not be used for matters of operational convenience, or commercial expediency and these arrangements shall be reviewed to ensure they remain appropriate for future phases on the project. A.3. The process follows the principles of the Nuclear Safety Committee meeting set out in these Terms of Reference, however the following additional points shall also be followed for Urgent Safety Proposals:  Details of the proposal are submitted to the NSC Chairman.  If the NSC Chairman agrees that the “Urgent Safety Proposals” process is appropriate, s/he requests the NSC to provide advice under that process.  All endeavours will be made to consult a quorum of the NSC members; however, where consulting a quorum of NSC members is impracticable owing to the urgency of the safety proposal, as many members as is practicable will be consulted. This shall include at least the NSC Chairman, one independent NSC member and a representative from the SZC Project.  The NSC Chairman advises ONR as soon as practicable of the urgent safety proposal and the advice given by the Committee.  The NSC Chairman reports the advice provided to the NNB GenCo (SZC) Board. This advice is given in writing where practicable, or is confirmed in writing as soon as practicable.  Following review by the NSC Chairman, a copy of the record is sent to ONR within 14 calendar days of the meeting.  Further advice shall be obtained from the next planned and properly constituted meeting of the Committee. A.4. The steps identified in this Appendix are NNB GenCo (SZC)’s arrangements for “Urgent Safety Proposals” and shall be submitted to ONR for approval. The NSC shall not meet under these “Urgent Safety Proposals” without the aforesaid approval. A.5. Once approved, no alteration or amendment can be made to the approved arrangements for “Urgent Safety Proposals” unless the NSC has considered and ONR has approved such alteration or amendment.

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COMPANY DOCUMENT

NUCLEAR SITE LICENCE COMPLIANCE MATRIX -SIZEWELL C

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TABLE OF CONTENTS

1 INTRODUCTION ...... 4 1.1 Purpose ...... 4 1.2 Scope of Appendix A – Compliance Matrix for Licence Conditions ...... 4 1.3 Scope of Appendix B – Licence Instrument Recipients...... 4 1.4 References and Definitions ...... 5

2 COMPLIANCE APPROACH ...... 6 2.1 Matrix Format ...... 6

3 PEOPLE ...... 8 3.1 Responsible Persons ...... 8

APPENDIX A -LICENCE CONDITIONS...... 9

APPENDIX B- LICENCE INSTRUMENT RECIPIENTS ...... 88

APPENDIX C - ADOPTION PHASE...... 94

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1 INTRODUCTION

1.1 Purpose This document summarises how NNB GenCo (SZC) complies (or intends to comply) with the 36 standard LCs attached to Schedule 2 of the NSL for SZC. For each condition attached to the NSL, this document identifies the NNB GenCo (SZC) compliance owner who has responsibility for ensuring compliance and the documents in which those arrangements are described. This document is the master source for references to the compliance arrangements. Where the requirements are satisfied by arrangements that are procedures, the IMS provides links between the compliance procedures available in the IMS and the NSL Conditions.

1.2 Scope of Appendix A – Compliance Matrix for Licence Conditions To meet the needs of the NSL for SZC, management arrangements have been identified, developed and implemented, which, since the point of NSL Granting, provide compliance with the 36 LCs. [Ref 1] This document sets out references to those management arrangements. Where arrangements have not been prepared by virtue of the site lifecycle, arrangements that will be implemented in later phases to meet the requirements of the NSL are identified. This document will be revised before each lifecycle phase (Non-Active Commissioning, Active Commissioning, Operation and Decommissioning) to reflect compliance. The Compliance Matrix in Appendix A provides information regarding compliance with each LC, including:  Roles, primarily responsible for making and maintaining adequate provisions for compliance, where in brackets this shows who will undertake the roles post FID, once appointed.;  Management Arrangements and, if appropriate, section references; and  Commentary, where appropriate.

1.3 Scope of Appendix B – Licence Instrument Recipients The Compliance Matrix in Appendix B provides information regarding Licence Instrument (LI) Recipients per LC. This table contains recipients for LCs with full arrangements implemented as well as those currently with proportionate arrangements. This will be updated for each stage of the project to ensure it remains up to date.

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In all LI cases, the Compliance Owner shall be responsible for responding to the Office for Nuclear Regulation (ONR).  NNB GenCo (SZC) post holders identified within Appendix A and Appendix B have the responsibility to receive, action and respond to LIs associated with the identified LC.  LIs are the mechanism by which the ONR applies both primary and derived powers on a nuclear site licensee. NNB GenCo (SZC) will receive and be expected to respond to LIs.  Appendix B establishes those post holders against each LC that may receive, and are expected to action a LI, if appropriate. The Appendix only includes LC clauses that contain primary powers or enable derived powers to be used within NNB GenCo (SZC)’s arrangements.  Appendix B supports the procedure on regulatory correspondence, Manage Interfaces with Regulators (Ref. 2)

1.4 References and Definitions

Ref Title Location Document No. The Licensing of Nuclear Installations and Licence Condition ONR http://www.onr.org.uk/silico 1 Handbook Website n.pdf NNB-209-PRO-000026 (SZC- 2 Manage Interfaces with Regulators EDRMS 100207786)

Term / Abbreviation Definition CDM Construction, Design and Manufacture Regulations DAP Duly Authorised Person EDRMS Electronic Document and Records Management System IMS Integrated Management System LC Licence Condition LI Licence Instrument NNB GenCo (SZC) NNB Generation Company (Sizewell C) Ltd NSL Nuclear Site Licence ONR Office for Nuclear Regulation ONR CNSS Office for Nuclear Regulation, Civil Nuclear Security and Safeguards PCSR Pre-Construction Safety Report POSR Pre-Operational Safety Report SSR Station Safety Report SZC Sizewell C

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2 COMPLIANCE APPROACH

NNB GenCo (SZC)’s approach towards complying with the 36 LCs is to develop, implement and maintain proportionate management arrangements that describe the execution of tasks related to NNB GenCo (SZC)’s activities on the SZC Project. Management Arrangements consist of company documentation, such as processes, procedures, work instructions, terms of reference, guidance documents, manuals, and schedules. The Compliance Matrix (Appendix A) maps where LC compliance is achieved.

2.1 Matrix Format LC compliance is presented in matrix format, referencing compliance arrangements that meet the requirements of LC clauses over the phases of the SZC Project. Shaded cells containing the term “N/A” denote phases where compliance arrangements are not required to be fully implemented. Appendix A presents the 36 compliance matrices in numerical order as listed below.  LC 1 Interpretation  LC 2 Marking of the Site Boundary  LC 3 Control of Property Transactions  LC 4 Restrictions on Nuclear Matter on the Site  LC 5 Consignment of Nuclear Matter  LC 6 Documents, Records, Authorities and Certificates  LC 7 Incidents on the Site  LC 8 Warning Notices  LC 9 Instructions to Persons on the Site  LC 10 Training  LC 11 Emergency Arrangements  LC 12 Duly Authorised and Other Suitably Qualified and Experienced Persons  LC 13 Nuclear Safety Committee  LC 14 Safety Documentation  LC 15 Periodic Review  LC 16 Site Plans, Designs and Specifications  LC 17 Management Systems

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 LC 18 Radiological Protection  LC 19 Construction or Installation of New Plant  LC 20 Modification to Design of Plant under Construction  LC 21 Commissioning  LC 22 Modification or Experiment on Existing Plant  LC 23 Operating Rules  LC 24 Operating Instructions  LC 25 Operational Records  LC 26 Control and Supervision of Operations  LC 27 Safety Mechanisms, Devices and Circuits  LC 28 Examination, Inspection, Maintenance and Testing  LC 29 Duty to Carry Out Tests, Inspections and Examinations  LC 30 Periodic Shutdown  LC 31 Shutdown of Specified Operations  LC 32 Accumulation of Radioactive Waste  LC 33 Disposal of Radioactive Waste  LC 34 Leakage and Escape of Radioactive Material and Radioactive Waste  LC 35 Decommissioning  LC 36 Organisational Capability

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3 PEOPLE

3.1 Responsible Persons

Role Responsibility Updating this document on a periodic basis to ensure that reference is provided to the Licencing appropriate management arrangements. Ensuring links to, and between, management arrangements within the IMS are Business maintained and notified to the appropriate Process Owner if amended. Responsible for all LIs received in association with the NSL. Appendix B details the Company Secretary responsibilities within the business for responding to these LIs. Ensuring that the arrangements quoted for compliance are reviewed and/or maintained Compliance Owners on a regular basis to ensure they are adequate for compliance with the NSL conditions and that the project is complying with them.

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APPENDIX A -LICENCE CONDITIONS.

This section contains a listing of licence conditions with a descriptor of phases and adoption processes.

Licence Condition 1 – Interpretation

In the conditions set out in this Schedule Safety, The compliance to this licence, unless the context Licencing and arrangements otherwise requires, the following Assurance implemented by NNB expressions have the meanings hereby Director GenCo (SZC) to comply respectively assigned to them, that is to with the 36 standard say – licence conditions include and reference, where required, relevant and "commissioning" means the process during appropriate, the which the plant components and systems, expressions and meanings

having been constructed or modified, are provided in this clause. made operational and verified to be in No specific arrangements are required under this Licence Condition accordance with the design assumptions and to have met the appropriate safety criteria;

"excepted matter" has the meaning assigned thereto in the Nuclear Installations Act 1965 (as amended) and the Nuclear Installations (Excepted Matter)

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Regulations 1978 made thereunder;

"the Executive" means the Health and Safety Executive;

"experiment" means any test or non- routine activity other than an activity carried out pursuant to conditions 21 and 28;

"installation" means "nuclear installation" and has the meaning assigned thereto in the Nuclear Installations Act 1965 (as amended);

"the licensee" and "the site" each has the meaning assigned thereto in paragraph 1 of this licence;

"modification" means any alteration to buildings, plants, operations, processes or safety cases and includes any replacement, refurbishment or repairs to existing buildings, plants or processes and alterations to the design of plants during the period of construction;

"nuclear matter" and "relevant site" each has the meaning assigned thereto in the Nuclear Installations Act 1965 (as

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“nuclear safety committee" means any nuclear safety committee established pursuant to condition 13 of this Schedule;

“ONR” means the Office for Nuclear Regulation

"operations" includes maintenance, examination, testing and operation of the plant and the treatment, processing, keeping, storing, accumulating or carriage of any radioactive material or radioactive waste and "operating" and "operational " shall be construed accordingly;

“property transaction” means any property transaction including a transfer, conveyance, assignment, demise, letting, under-letting, parting with possession, sharing occupation or use, or granting or reserving any property licence, easement or wayleave over or in relation to the site or any part of it, but excluding a right of access or any right of occupation, use or possession to or with a party performing statutory, regulatory or international obligations, or a party delivering contracted services solely to or for the benefit of the licensee, in relation to that

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nuclear licensed site.

“radioactive material” has the meaning, disregarding the exception in paragraph 9 (contaminated articles or substances) of Part 2 of Schedule 23 to the Environmental Permitting (England and Wales) Regulations 2016, given in paragraph 3 of that Part of that Schedule to those Regulations;

“radioactive waste” has the meaning assigned thereto in paragraph 3 of Part 2 of Schedule 23 to the Environmental Permitting (England and Wales) Regulations 2016;

"safety" refers to the safety of persons whether on or off the site;

"safety case" means the document or documents produced by the licensee in accordance with condition 14 of this Schedule. 1(2) In these conditions except where the Safety, Clause (b) requires that all context otherwise requires Licencing and matters relating to licence Assurance instruments shall be Director conveyed by formal (a) any reference to the singular shall correspondence No specific arrangements are required under this Licence Condition include the plural and vice versa and any reference to the masculine shall include the feminine;

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(b) any reference to any arrangement, agreement, approval, consent, direction, specification, notification or any formal communication between ONR and the licensee (and vice versa) shall be deemed to be a reference to a written document;

(c) any reference to a numbered condition is a reference to the condition so numbered in this Schedule. 1(3) Where in these conditions ONR requires Safety, The ONR may use this any matter to be approved or to be carried Licencing and clause to modify, revise or out only with its consent or to be carried Assurance withdraw licence out as it directs ONR may: Director instruments previously Manage Interfaces with Regulators issued. For example, (NNB-209-PRO-000026 (SZC- 100207786)) where ONR SPECIFY an (Manage Incoming Regulatory Correspondence and Notifications) (a) from time to time modify, revise, or arrangement for withdraw either wholly or in part any such APPROVAL, they may use (Manage Outgoing Regulatory Correspondence) approval, direction or consent; LC1 (3) to withdraw the APPROVAL via a licence Control Regulatory Approved Management Arrangements instrument. (b) approve either wholly or in part any (NNB-102-PRO-000064 (SZC- 100207813)) modification or revision or proposed modification or revision to any matter for (Withdraw Regulatory Approval Controls from Management Arrangements) the time being approved.

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Licence Condition 2 – Marking of the Site Boundary

Arrangements for Compliance Person Responsible Non-Active Active LC Licence Condition for Compliance Comments Decommissioning Pre-FID Phase Construction Phase Commissioning Commissioning Operation Phase Arrangements Phase Phase Phase

2(1) The licensee shall make and implement Safety, Licencing Unauthorised persons are prevented N/A adequate arrangements to prevent and Assurance from entering the nuclear licensed site (No site SZC Equivalent of “Provide Limited Access Managed Service Worker Access to Hinkley Point C unauthorised persons from entering the Director through the implementation of physical ownership) site or, if so directed by ONR, from barriers and access control. NNB-301-PRO-000228 (Engineering and Covered by SZB entering such part or parts thereof as ONR Delivery Director Issuing access control passes also Recruit Contractor may specify. access. SZC) enables visible indication of NNB-302-PRO-000020_(SZC equivalent 100208158) authorisation. Recruit Employee The system that supports the access NNB-302-PRO-000003 (SZC equivalent 100208145) passes enables confirmation of authorisation NNB-302-PRO-000004 (SZC equivalent 100208148) SZC Equivalent of “Maintain Nuclear Site Licence Boundary” NNB-209-PRO-000081 Manage Interfaces with Regulators NNB-209-PRO-000026 (SZC Equivalent 100207786) The above will be implemented in the early construction phase, when the site is acquired and construction security fence is established, and prior to safety related concrete.

2(2) The licensee shall submit to ONR for Safety, Licencing None approval such part or parts of the and Assurance aforesaid arrangements as ONR may Director Control Regulatory Approved Management Arrangements specify. (Engineering and NNB-102-PRO-000064 (SZC 100207813) Delivery Director SZC)

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Licence Condition 2 – Marking of the Site Boundary

2(3) The licensee shall ensure that once Safety, Licencing None approved no alteration or amendment is and Assurance made to the approved arrangements Director Control Regulatory Approved Management Arrangements unless ONR has approved such alteration (Engineering and NNB-102-PRO-000064 (SZC/ 100207813) or amendment. Delivery Director SZC)

2(4) The licensee shall mark the boundaries of Engineering and Initially excluded: NSL boundary the site by fences or other appropriate Delivery Director markings will not be implemented at means and any such fences or other (Engineering and the point the Nuclear Site Licence is * Licence Condition 2(4) will be added to the NSL before fuel receipt when the site security fence is erected. This will means used for this purpose shall be Delivery Director Granted. legally require NNB to mark and maintain the NSL boundary, an alleviation will be requested as per HPC practice.. N/A properly maintained. SZC) SZC Equivalent of “Maintain Nuclear Site Licence Boundary” No site Ownership NNB-209-PRO-000081

2(5) The licensee shall, if so directed by ONR, Engineering and None erect appropriate fences on the site in Delivery Director. such positions as ONR may specify and (Engineering and Manage Interfaces with Regulators shall ensure that all such fences are Delivery Director NNB-209-PRO-000026 (SZC/ 100207786) properly maintained. SZC) (Manage Incoming Regulatory Correspondence and Notifications)

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Licence Condition 3 – Control of Property Transactions

Comments Arrangements for Compliance Person Responsible Non-Active LC Licence Condition for Compliance Active Commissioning Decommissioning Pre-FID Phase Construction Phase Commissioning Operation Phase Arrangements Phase Phase Phase

3(1) The licensee shall make and Company Secretary Notification of any proposal to implement adequate arrangements convey land ownership or confer (‘arrangements’) to control all rights regarding any part of the SZC property transactions affecting the Licensed Site will be given to the site or any part of the site to ensure ONR. that the licensee remains in overall NNB GenCo (SZC) shall not convey, Control of Licensed Site Property Transactions- NNB-307-PRO-000018 control of the site. assign, transfer, let or part with

possession of any part of SZC Licensed Site or any part thereof or grant any licence thereof without ONR consent.

3(2) The arrangements shall include Company Secretary NNB GenCo (SZC) will categorise the provision for the classification of all property transactions according to property transactions according to their safety significance their safety significance and their impact on the licensee’s control of Control of Licensed Site Property Transactions- NNB-307-PRO-000018 the site. The arrangements shall Where categorisation is of a include a requirement for the significant level, documentation will Manage Interfaces with Regulators - NNB-209-PRO-000026 (SZC/ 100207786) provision of adequate be submitted to ONR for their documentation to justify the consideration. (Manage Outgoing Regulatory Correspondence) classification of property transactions and shall where appropriate provide for the submission of this documentation to ONR.

3(3) The licensee shall submit to ONR for Company Secretary None approval such part or parts of the Control Regulatory Approved Management Arrangements arrangements as ONR may specify. NNB-102-PRO-000064 (SZC/ 100207813)

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Licence Condition 3 – Control of Property Transactions

3(4) The licensee shall ensure that once Company Secretary None approved no alteration or amendment is made to the approved Control Regulatory Approved Management Arrangements arrangements unless ONR has approved such alteration or NNB-102-PRO-000064 (SZC/ 100207813) amendment.

3(5) The licensee shall not transfer its Company Secretary NNB GenCo (SZC) must obtain formal freehold or assign its leasehold consent from ONR before a transfer interest in the site or any part of the of the freehold or assignment of site without the consent of ONR. In leasehold interest, in any part of the addition, if ONR so specifies the site. Control of Licensed Site Property Transactions - NNB-307-PRO-000018 licensee shall not carry out any property transaction, or any property Manage Interfaces with Regulators- NNB-209-PRO-000026 (SZC/ 100207786) transaction of the description or ONR may specify further property descriptions specified by ONR, transactions that also require its without the consent of ONR. formal consent.

3(6) The licensee, if so directed by ONR, Company Secretary NNB GenCo (SZC) shall, if so directed, shall not complete the property halt property transactions and shall transaction specified in that direction not recommence without ONR without the consent of ONR.” consent. Manage Interfaces with Regulators- NNB-209-PRO-000026 (SZC/ 100207786)

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Licence Condition 4 – Restrictions on Nuclear Matter on the Site

Arrangements for Compliance Person Responsible Active LC Licence Condition for Compliance Comments Non-Active Decommissioning Pre-FID Phase Construction Phase Commissioning Operation Phase Arrangements Commissioning Phase Phase Phase

4(1) The licensee shall ensure that no Engineering and Nuclear matter supporting nuclear matter is brought onto the Delivery Director construction activities may be brought SZC equivalent of site except in accordance with (SZC) onto the SZC Site. SZC equivalent of N/A “Control Nuclear Matter” adequate arrangements made by the The Control Nuclear Matter “Updated Arrangement: Control Nuclear Matter” licensee for this purpose. (No site ownership) NNB-308-PRO-000002 procedure will be updated and NNB-308-PRO-000002 implemented prior to the arrival of *Control of any sources on licenced site- nuclear fuel.

NNB GenCo (SZC) will implement arrangements for the receipt of N/A until Fuel dispatch from suppliers to site Arrangement: Management of Nuclear Fuel authorised consignments of nuclear fuel onto the SZC Site.

4(2) The licensee shall ensure that no Engineering and Nuclear matter on the SZC Site Arrangement: Management of Nuclear Fuel nuclear matter is stored on the site Delivery Director supporting construction activities is SZC Equivalent of Updated Arrangement: Control Nuclear Matter except in accordance with adequate (SZC) managed using the Control Nuclear N/A “Control Nuclear Matter” arrangements made by the licensee Matter procedure, which will be NNB-308-PRO-000002 for this purpose. updated prior to nuclear fuel delivery (No Site Ownership) NNB-308-PRO-000002 Arrangement: On Site Storage of Radioactive Waste & Irradiated to SZC. Two further arrangements * prior to use of any sources on licenced site Fuel will be implemented at that time.

4(3) The licensee shall submit to ONR for Engineering and None Control Regulatory Approved Management Arrangements approval such part or parts of the Delivery Director aforesaid arrangements as ONR may (SZC) NNB-102-PRO-000064 (SZC/ 100207813) specify.

4(4) The licensee shall ensure that once Engineering and None approved no alteration or Delivery Director Control Regulatory Approved Management Arrangements amendment is made to the approved (SZC) NNB-102-PRO-000064 (SZC/ 100207813) arrangements unless ONR has approved such alteration or amendment.

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Licence Condition 4 – Restrictions on Nuclear Matter on the Site

4(5) For new installations, if ONR so Engineering and We expect ONR to permission the specifies, the licensee shall ensure Delivery Director delivery of fuel to site under LC 21(4) that no nuclear matter intended for (SZC) instead of LC 4. Manage Interfaces with Regulators use in connection with the new NNB-209-PRO-000026 (SZC/ 100207786) installation is brought onto the site (Manage Incoming Regulatory Correspondence and Notifications) for the first time without the consent of ONR.

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Licence Condition 5 – Consignment of Nuclear Matter

Arrangements for Compliance Person Responsible for LC Licence Condition Compliance Comments Non-Active Active Commissioning Decommissioning Pre-FID Phase Construction Phase Operation Phase Arrangements Commissioning Phase Phase Phase

5(1) The licensee shall not consign nuclear Engineering and None SZC Equivalent of SZC Equivalent of matter (other than excepted matter and Delivery Director (SZC) “Consign Nuclear Matter” radioactive waste) to any place in the “Updated Arrangement: Control Nuclear Matter” NNB-205-PRO-000145 United Kingdom other than a relevant site NNB-308-PRO-000002 except with the consent of ONR. (Obtain Office for Nuclear Regulation Consent N/A Full Arrangement: Transport of Radioactive Material prior to use of sources on site) (no Site Ownership, no Arrangement: Management of Nuclear Fuel nuclear matter on site) Manage Interfaces with Regulators NNB-209-PRO-000026 (SZC/ 100207786) (Manage Incoming Regulatory Correspondence and Notifications)

5(2) The licensee shall keep a record of all Engineering and NNB GenCo (SZC) Arrangements will nuclear matter (including excepted matter Delivery Director (SZC) ensure records are made and preserved and radioactive waste) consigned from the for each nuclear fuel consignment N/A Consign Nuclear Matter site and such record shall contain containing particulars of the amount, (no Site Ownership, no NNB-205-PRO-000145 particulars of the amount, type and form of type and form of such nuclear matter, Full Arrangement: Transport of Radioactive Material such nuclear matter, the manner in which it the manner in which it was packed, the nuclear matter on site) (Update Nuclear Matter Record Sheet- prior to was packed, the name and address of the name and address of the consignee and use of sources on site) person to whom it was consigned and the the date when it left site. date when it left the site.

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Licence Condition 5 – Consignment of Nuclear Matter

5(3) The licensee shall ensure that the aforesaid Engineering and Documents and Records Code of Practice record is preserved for 30 years from the Delivery Director (SZC) NNB-301-COP-000001 date of dispatch or such other period as ONR may approve except in the case of any N/A consignment or part thereof subsequently High Level Records Retention Schedule stolen, lost, jettisoned or abandoned, in (no Site Ownership, no NNB-301-STR-000010 which case the record shall be preserved nuclear matter on site)

for a period of 50 years from the date of such theft, loss, jettisoning or abandoning. Manage Interfaces with Regulators NNB-209-PRO-000026 (SZC/ 100207786) (Manage Incoming Regulatory Correspondence and Notifications)

Licence Condition 6 – Documents, Records, Authorities and Certificates

6(1) The licensee shall make adequate records to Finance Director Records are identified within each demonstrate compliance with any of the company procedure referenced in this Documents and Records Code of Practice- NNB-301-COP-000001 conditions to this licence. matrix and summarised in the Record

Retention Schedule. High Level Records Retention Schedule -NNB-301-STR-000010 The Record Retention Schedule is a snapshot of records identified within management arrangements.

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Licence Condition 6 – Documents, Records, Authorities and Certificates

6(2) Without prejudice to any other requirement Finance Director The Record Retention Schedule is a of the conditions attached to this licence, snapshot of records identified within the licensee shall make and implement management arrangements. adequate arrangements to ensure that Documents and Records Code of Practice- NNB-301-COP-000001 every document required, every record made, every authority, consent or approval High Level Records Retention Schedule -NNB-301-STR-000010 granted and every direction or certificate Manage Interfaces with Regulators -NNB-209-PRO-000026 (SZC/ 100207786) issued in pursuance of the conditions attached to this licence is preserved for 30 years or such other periods as ONR may approve.

6(3) The licensee shall submit to ONR for Finance Director None Control Regulatory Approved Management Arrangements approval such part or parts of the aforesaid arrangements as ONR may specify. NNB-102-PRO-000064 (SZC/ 100207813)

6(4) The licensee shall ensure that once Finance Director None approved no alteration or amendment is Control Regulatory Approved Management Arrangements made to the approved arrangements unless ONR has approved such alteration or NNB-102-PRO-000064 (SZC/ 100207813) amendment.

6(5) The licensee shall furnish to ONR copies of Finance Director None Manage Interfaces with Regulators any such document, record, authority or NNB-209-PRO-000026 (SZC/ 100207786) certificate as ONR may specify.

Licence Condition 7 – Incidents on the Site

LC Licence Condition Person Comments Arrangements for Compliance

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Responsible for Non-Active Active Compliance Decommissioning Pre-FID Phase Construction Phase Commissioning Commissioning Operation Phase Arrangements Phase Phase Phase

7(1) The licensee shall make and implement Safety, Licencing The Enable Organisational Learning adequate arrangements for the notification, and Assurance procedure defines the process for recording, investigation and reporting of Director recording incidents. Enable Organisational Learning such incidents occurring on the site: The Event Categorisation and Offsite Reporting guidance document provides NNB-104-PRO-000011_(SZC/ 100208059) (a) As is required by any other condition arrangements for the notification and Shadow working Event Categorisation, Offsite Reporting and Notification - NNB-308-GUI-000082 attached to this licence; reporting of incidents. phase. Investigate Incidents- NNB-308-PRO-000040 (SZC/ 100207765) The Investigate Incidents procedure Manage Interfaces with Regulators- NNB-209-PRO-000026 (SZC/ 100207786) defines the process for investigating (b) As ONR may specify; incidents. (Manage Incoming Regulatory Correspondence and Notifications)

7(2) The licensee shall submit to ONR for Safety, Licencing None approval such part or parts of the aforesaid and Assurance Control Regulatory Approved Management Arrangements arrangements as ONR may specify. Director NNB-102-PRO-000064 (SZC/ 100207813)

7(3) The licensee shall ensure that once Safety, Licencing None approved no alteration or amendment is and Assurance Control Regulatory Approved Management Arrangements made to the approved arrangements unless Director NNB-102-PRO-000064 (SZC/ 100207813) ONR has approved such alteration or amendment.

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Licence Condition 8 – Warning Notices

Arrangements for Compliance Person Responsible for LC Licence Condition Comments Non-Active Active Compliance Decommissioning Pre-FID Phase Construction Phase Commissioning Commissioning Operation Phase Arrangements Phase Phase Phase

8 The licensee shall ensure that suitable and Engineering and Sufficient warning notices are located sufficient notices are kept on the site for Delivery Director at appropriate positions to inform the purposes of informing persons thereon SZC persons of: of each of the following matters, that is to (a) the meaning of any warning signal. say: (b) the location of any emergency exit. (a) the meaning of any warning signal used on the site; (c) the measures to be taken in the event of a fire or other emergency. SZC equivalent of (b) the location of any exit from N/A “Provide Nuclear Site Licence Warning Notices” any place on the site, being an exit provided Warning notices are designed and for use in the event of an emergency; constructed in accordance with (no Site Ownership) NNB-307-PRO-000019 appropriate specifications. (c) the measures to be taken by such persons in the event of fire breaking Each warning notice is appropriate for out on the site or in the event of any other the specific hazard to which it relates. emergency; Warning notices are inspected at a and that such notices are kept posted in defined frequency and maintained as such positions and in such characters as to required. be conveniently read by those persons.

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Licence Condition 9 – Instructions to Persons on the Site

9 The licensee shall ensure that every person Engineering and Safety instructions are provided to authorised to be on the site receives Delivery Director persons requiring unescorted access to adequate instruction (to the extent that this SZC the SZC Site through SZC Induction is necessary having regard to the training. circumstances of that person being on the site) as regards the risks and hazards Provide Managed Service Worker Access- NNB-102-PRO-000065 associated with the plant and its operation, the precautions to be observed in (Provide SZC Project Introduction) connection therewith and the action to be SZC Equivalent of “Provide Limited Access Managed Service Worker Access to Hinkley Point C- NNB-301-PRO-000228 taken in the event of an accident or (Provide SZC Project Introduction) emergency on the site. N/A Provide Temporary Managed Service Worker Access- NNB-205-PRO-000117 (No Site Ownership) (Provide Temporary Managed Service Worker Introduction) Covered by local induction as part of Re-Hire Hinkley Point C Managed Service Worker- NNB-102-PRO-000085 CDM Regulations (Provide Managed Service Worker Induction) and setting to work. Recruit Contractor- NNB-302-PRO-000020 (SZC/ 100208158) (Allocate Contractor On-Boarding Training) Recruit Employee- NNB-302-PRO-000003 (SZC/ 100208145) (Allocate Employee On-Boarding Training)

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Safety instructions are provided to N/A visitors through a visitor’s safety brief. (No Site Ownership) SZC equivalent of “Manage Visitors NNB-308-PRO-000008” Covered by local induction as part of (Conduct Site Briefing) CDM Regulations and setting to work

Licence Condition 10 – Training

10(1) The licensee shall make and implement Safety, Licencing Training for roles that may affect safety Develop New Training adequate arrangements for suitable and Assurance is identified, generated and delivered training of all those on site who have Director using a systematic approach to training NNB-104-PRO-000014 (SZC/ 100208002) responsibility for any operations which may (SAT). Shadow working will be (Pre-Operations affect safety. Director- later) undertaken up to FID and the start of construction phase Covered by Implement Training Events Requirements of NNB-205-PRO-000020 (SZC/ 100208008) CDM Regulations and setting to work.

Evaluate Training

NNB-205-PRO-000021 (SZC/ 100208015)

10(2) The licensee shall submit to ONR for Safety, Licencing None approval such part or parts of the aforesaid and Assurance arrangements as ONR may specify. Director Control Regulatory Approved Management Arrangements (Pre-Operations NNB-102-PRO-000064 (SZC/ 100207813) Director later)

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Licence Condition 10 – Training

10(3) The licensee shall ensure that once Safety, Licencing None approved no alteration or amendment is and Assurance Director made to the approved arrangements unless Control Regulatory Approved Management Arrangements ONR has approved such alteration or (Pre-Operations NNB-102-PRO-000064 (SZC/ 100207813) amendment. Director later)

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Licence Condition 11 – Emergency Arrangements

11(1) Without prejudice to any other requirements Safety, Licencing Proportionate emergency of the conditions attached to this licence the and Assurance arrangements are, and will continue to licensee shall make and implement adequate be implemented throughout the SZC Director Establish and Maintain Emergency Establish and Maintain Emergency Arrangements arrangements for dealing with any accident lifecycle. Arrangements (Engineering and or emergency arising on the site and their NNB-308-PRO-000043 (SZC/ 100232454) Delivery Director effects. Covered by NNB-308-PRO-000043 SZC) Requirements of and (SZC/ 100232454) CDM Regulations SZC Emergency Plan and SZB NSL Revised to reflect growing Workforce (REPPIR)

11(2) The Licensee shall submit to ONR for Safety, Licencing There is an expectation that ONR will approval such part or parts of the aforesaid and Assurance specify parts of the Emergency arrangements as ONR may specify. Director Arrangements prior to the start of Control Regulatory Approved Management Arrangements Active Commissioning. (Engineering and NNB-102-PRO-000064 (SZC/ 100207813) Delivery Director SZC)

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Licence Condition 11 – Emergency Arrangements

11(3) The licensee shall ensure that once approved Safety, Licencing None no alteration or amendment is made to the and Assurance approved arrangements unless ONR has Director Control Regulatory Approved Management Arrangements approved such alteration or amendment. (Engineering and NNB-102-PRO-000064 (SZC/ 100207813) Delivery Director SZC)

11(4) Where any such arrangements require the Safety, Licencing External organisations must be assistance or cooperation of, or render it and Assurance consulted in the development of SZC necessary or expedient to make use of the Director emergency arrangements. services of any person, local authority or Establish and Maintain Emergency Arrangements other body the licensee shall ensure that (Engineering and each person, local authority or other body is Delivery Director Covered by local NNB-308-PRO-000043 (SZC/ 100232454) consulted in the making of such SZC) instructions and SZB plan (Review Emergency Planning Inputs and their RACI Dependencies) arrangements

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Licence Condition 11 – Emergency Arrangements

11(5) The licensee shall ensure that such Safety, Licencing NNB GenCo (SZC) will ensure exercises SZC equivalent of “Plan and Administer Emergency Exercises” arrangements are rehearsed at such and Assurance are conducted at appropriate intervals intervals and to such extent as ONR may Director unless otherwise specified by ONR. NNB-308-PRO-000042 specify or, where ONR has not so specified, Covered by local (Update and Issue Emergency Exercise Programme) as the licensee considers necessary. (Engineering and Delivery Director instructions and SZB Manage Interfaces with Regulators SZC) plan NNB-209-PRO-000026 (SZC/ 100207786)

(Manage Incoming Regulatory Correspondence and Notifications)

11(6) The licensee shall ensure that such Safety, Licencing The adequacy (selection, training, arrangements include procedures to ensure and Assurance competency and availability) of that all persons in his employ who have Director emergency response personnel is Establish and Maintain Emergency Arrangements duties in connection with such arrangements reviewed against the requirements of Covered by local (Engineering and are properly instructed in the performance emergency arrangements. Deficiencies instructions and SZB NNB-308-PRO-000043 (SZC/ 100232454) Delivery Director of the same, in the use of the equipment are addressed through personnel plan. required and the precautions to be observed SZC) selection, competency management (Review Emergency Response Personnel) in connection therewith. and training.

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Licence Condition 12 – Duly Authorised and Other Suitably Qualified and Experienced Persons

12(1) The licensee shall make and implement Safety, Licencing The Management of Roles and Develop Role And Training Profiles adequate arrangements to ensure that only and Assurance Competencies procedures define the suitably qualified and experienced persons Director process for managing the competency NNB-207-PRO-000002 (SZC/ 100207760) perform any duties which may affect the of persons undertaking safety-related

safety of operations on the site or any other (Pre-Operations roles. Director) duties assigned by or under these conditions Assess Individual Competency or any arrangements required under these conditions. NNB-102-PRO-000111 (SZC/ 100207753)

12(2) The aforesaid arrangements shall also Safety, Licencing Arrangements for the identification and provide for the appointment, in appropriate and Assurance notification of DAPs will be in place for Arrangement: Manage Authorisations cases, of duly authorised persons to control Director the start of the Non-Active N/A and supervise operations which may affect Commissioning phase. Arrangement: Management of Operational Competency plant safety. (Pre-Operations Director)

12(3) The licensee shall submit to ONR for Safety, Licencing None approval such part or parts of the aforesaid and Assurance Control Regulatory Approved Management Arrangements arrangements as ONR may specify. Director NNB-102-PRO-000064 (SZC/ 100207813)

(Pre-Operations Director)

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Licence Condition 12 – Duly Authorised and Other Suitably Qualified and Experienced Persons

12(4) The licensee shall ensure that once approved Safety, Licencing None no alteration or amendment is made to the and Assurance Control Regulatory Approved Management Arrangements approved arrangements unless ONR has Director NNB-102-PRO-000064 (SZC/ 100207813) approved such alteration or amendment. (Pre-Operations Director)

12(5) The licensee shall ensure that no person Safety, Licencing Arrangements for the identification and Arrangement: Manage Authorisations continues to act as a duly authorised person and Assurance notification of DAPs will be in place for if, in the opinion of ONR, he is unfit to act in Director the start of the Non-Active Arrangement: Management of Operational Competency that capacity and ONR has notified the Commissioning phase. licensee to that effect. (Pre-Operations N/A Manage Interfaces with Regulators Director) NNB-209-PRO-000026 (SZC/ 100207786)

(Manage Incoming Regulatory Correspondence and Notifications)

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Licence Condition 13 – Nuclear Safety Committee

13(1) The licensee shall establish a nuclear safety committee or Safety, Licencing The NSC shall be SZC – Nuclear Safety Committee Terms of Reference and Assurance committees to which it shall refer for consideration and consulted for advice and 100197655 advice the following: Director consideration on matters, documents and [See note at foot of Licence Condition 13 section (a) all matters required by or under these conditions to be arrangements. (Sections A.1 & B.2) referred to a nuclear safety committee;

(b) such arrangements or documents required by these Work Instruction: Nuclear Safety Committee conditions as ONR may specify and any subsequent alteration or amendment to such specified arrangements NNB-102-WIN-000007 or documents;

(c) any matter on the site affecting safety on or off the site which ONR may specify; and Manage Interfaces with Regulators

(d) any other matter which the licensee considers should NNB-209-PRO-000026 (SZC/ 100207786) be referred to a nuclear safety committee. (Manage Incoming Regulatory Correspondence and Notifications)

13(2) The licensee shall submit to ONR for approval the terms of Safety, Licencing None SZC – Nuclear Safety Committee Terms of Reference reference of any such nuclear safety committee and shall and Assurance 100197655 not form a nuclear safety committee without the Director aforesaid approval. Manage Interfaces with Regulators NNB-209-PRO-000026 (SZC/ 100207786) (Manage Outgoing Regulatory Correspondence)

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Licence Condition 13 – Nuclear Safety Committee

13(3) The licensee shall ensure that once approved no Safety, Licencing None SZC – Nuclear Safety Committee Terms of Reference alteration or amendment is made to the terms of and Assurance reference of such a nuclear safety committee, unless ONR Director 100197655 has approved such alteration or amendment. Control Regulatory Approved Management Arrangements NNB-102-PRO-000064 (SZC/ 100207813)

13(4) The licensee shall appoint at least seven persons as Safety, Licencing None members of a nuclear safety committee including one or and Assurance more members who are independent of the licensee's Director HPC – Nuclear Safety Committee Terms of Reference operations and shall ensure that a least five members are 100197655 present at each meeting including at least one independent member.

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Licence Condition 13 – Nuclear Safety Committee

13(5) The licensee shall furnish to ONR the name, qualifications, Safety, Licencing None particulars of current posts held and the previous relevant and Assurance SZC – Nuclear Safety Committee Terms of Reference experience of every person he appoints as a member of Director 100197655 any nuclear safety committee forthwith after making such appointment. Notwithstanding such appointment the licensee shall ensure that a person so appointed does not Work Instruction: Nuclear Safety Committee remain a member of any nuclear safety committee if ONR NNB-102-WIN-000007 notifies the licensee that it does not agree to the appointment.

Manage Interfaces with Regulators NNB-209-PRO-000026 (SZC/ 100207786) (Manage Incoming Regulatory Correspondence and Notifications) (Manage Outgoing Regulatory Correspondence)

13(6) The licensee shall ensure that the qualifications, current Safety, Licencing None

posts held and previous relevant experience of the and Assurance members of any such committee, taken as a whole, are Director SZC – Nuclear Safety Committee Terms of Reference such as to enable that committee to consider any matter 100197655 likely to be referred to advise the licensee authoritatively

and, so far as practicable, independently.

13(7) The licensee shall ensure that a nuclear safety committee Safety, Licencing None shall consider or advise only during the course of a and Assurance SZC – Nuclear Safety Committee Terms of Reference properly constituted meeting of that committee. Director 100197655

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Licence Condition 13 – Nuclear Safety Committee

13(8) The licensee shall send to ONR within 14 days of any Safety, Licencing None SZC – Nuclear Safety Committee Terms of Reference meeting of any such committee a full and accurate record and Assurance 100197655 of all matters discussed at the meeting including in Director particular any advice given to the licensee. Work Instruction: Nuclear Safety Committee NNB-102-WIN-000007

Manage Interfaces with Regulators NNB-209-PRO-000026 (SZC/ 100207786) (Manage Outgoing Regulatory Correspondence)

13(9) The licensee shall furnish to ONR copies of any document Safety, Licencing None any category of documents considered at any such and Assurance SZC – Nuclear Safety Committee Terms of Reference meetings that ONR may specify. Director 100197655

Manage Interfaces with Regulators NNB-209-PRO-000026 (SZC/ 100207786) (Manage Incoming Regulatory Correspondence and Notifications) (Manage Outgoing Regulatory Correspondence)

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Licence Condition 14 – Safety Documentation

14(1) Without prejudice to any other requirements Engineering and The Manage Safety Reports SZC Equivalent of “Manage Safety Reports” of the conditions attached to this licence the Delivery Director. procedure defines the process for NNB-202-PRO-000005 licensee shall make and implement adequate producing, reviewing and approving arrangements for the production and (Post FID- safety reports. assessment of safety cases consisting of Technical documentation to justify safety during the Director) The equivalent process for construction safety justifications is as N/A design, construction, manufacture, Manage Construction Safety Justifications commissioning, operation and described in the Manage No construction in NNB-202-PRO-000016 decommissioning phases of the installation. Construction Safety Justification this phase. procedure.

Updates to safety cases other than a Control Modifications During Construction and Commissioning revision to a staged safety report will be managed as a modification. NNB-202-PRO-000004 (Perform Review and Acceptance of the Design)

14(2) The licensee shall submit to ONR for approval Engineering and None Control Regulatory Approved Management Arrangements such part or parts of the aforesaid Delivery Director arrangements as ONR may specify. NNB-102-PRO-000064 (SZC/ 100207813)

14(3) The licensee shall ensure that once approved Engineering and None no alteration or amendment is made to the Delivery Director Control Regulatory Approved Management Arrangements approved arrangements unless ONR has NNB-102-PRO-000064 (SZC/ 100207813) approved such alteration or amendment.

14(4) The licensee shall furnish to ONR copies of any Engineering and None Manage Interfaces with Regulators such documentation as ONR may specify. Delivery Director NNB-209-PRO-000026 (SZC/ 100207786) (Manage Incoming Regulatory Correspondence and Notifications)

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Licence Condition 15 – Periodic Review

15(1) The licensee shall make and implement Engineering and NNB GenCo (SZC) will implement full adequate arrangements for the periodic Delivery arrangements for LC 15 prior to and systematic review and reassessment DirectorPost FID- operation. N/A Manage Safety Reports of safety cases. Technical Director) Operating Experience and the review of NNB-202-PRO-000005 Safety Cases is covered in the Manage Safety Reports procedure.

15(2) The licensee shall submit to ONR for Engineering and None Control Regulatory Approved Management approval such part or parts of the aforesaid Delivery Director N/A Arrangements arrangements as ONR may specify. NNB-102-PRO-000064 (SZC/ 100207813)

15(3) The licensee shall ensure that once Engineering and None approved no alteration or amendment is Delivery Director Control Regulatory Approved Management made to the approved arrangements N/A Arrangements unless ONR has approved such alteration NNB-102-PRO-000064 (SZC/ 100207813) or amendment.

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Licence Condition 15 – Periodic Review

15(4) The licensee shall, if so directed by ONR, Engineering and NNB GenCo (SZC) shall, where directed Manage Safety Reports carry out a review and reassessment of Delivery Director by the ONR, undertake a review of safety and submit a report of such review safety and submit a report to the ONR NNB-202-PRO-000005 and reassessment to ONR at such intervals, as appropriate. Manage Interfaces with Regulators within such a period and for such of the matters or operations as may be specified N/A NNB-209-PRO-000026 (SZC/ 100207786) in the direction. (Manage Incoming Regulatory Correspondence and Notifications)

(Manage Outgoing Regulatory Correspondence)

Licence Condition 16 – Site Plans, Designs and Specifications

16(1) The licensee shall submit to ONR an adequate Engineering and Drawing defining the SZC NSL plan of the site (hereinafter referred to as the Delivery Director boundary. Sizewell C Nuclear Site Licence Area Drawing No SZC-SZ0100-XX-000-DRW-100104 NSL boundary site plan) showing the location of the boundary of the licensed site and every building or plant on the site which might affect safety. Drawing defining the locations and footprint of buildings on the SZC Sizewell C Site Layout SZC-SZ0100-XX-000-DRW-100004 (rev 5) site.

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Licence Condition 16 – Site Plans, Designs and Specifications

The drawings above, when frozen, SZC equivalent of Manage Design Change shall be submitted to ONR. NNB-202-PRO-000033- to be implemented before FID

Manage Interfaces with Regulators

NNB-209-PRO-000026 (SZC/ 100207786)

(Manage Outgoing Regulatory Correspondence)

16(2) The licensee shall submit to ONR with the site Engineering and The List of Buildings provides a plan a schedule giving particulars of each such Delivery Director description and reference to the SZC-SZ0100-XX-000-REP-100039 (rev 1) building and plant thereon and the operations Hinkley Point C Site Layout associated therewith. drawing for each building within the SZC Site.

The List of Buildings, when frozen, Shadow working shall be submitted to the ONR. SZC Equivalent of Manage Design Change

NNB-202-PRO-000033- to be implemented before FID

(Issue Site Layout Drawings and Documents)

Manage Interfaces with Regulators

NNB-209-PRO-000026 (SZC- 100207786)

(Manage Outgoing Regulatory Correspondence)

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Licence Condition 16 – Site Plans, Designs and Specifications

16(3) If any changes are made on the site which Engineering and None Shadow Working affect the said buildings, plant or operations, Delivery Director the licensee shall forthwith send an amended SZC Equivalent of Manage Design Change site plan and schedule to ONR incorporating NNB-202-PRO-000033- before FID these changes. (Issue Site Layout Drawings and Documents)

Manage Interfaces with Regulators

NNB-209-PRO-000026 (SZC- 100207786)

(Manage Outgoing Regulatory Correspondence)

16(4) The licensee shall furnish to ONR such plans, Engineering and None Manage Interfaces with Regulators designs, specifications or other information Delivery Director relating to such buildings, plants and NNB-209-PRO-000026 (SZC- 100207786) operations as ONR may specify (Manage Incoming Regulatory Correspondence and Notifications)

(Manage Outgoing Regulatory Correspondence)

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Licence Condition 17 – Management Systems

17(1) Without prejudice to any other Finance Director The NNB GenCo (SZC) Integrated requirements of the conditions Management System complies with IAEA GS- attached to this licence, the licensee R-3, giving priority to safety. Management System Manual, 100200202 shall establish and implement management systems which give due priority to safety.

17(2) The licensee shall, within its Finance Director The Management System Manual, management systems, make and 100200202 defines the documentary Management System Manual, 100200202 implement adequate quality elements of the Integrated Management management arrangements in respect System, which includes arrangements for of all matters which may affect safety. matters that may affect safety.

17(3) The licensee shall submit to ONR for Finance Director None approval such part or parts of the Control Regulatory Approved Management Arrangements aforesaid management systems or part NNB-102-PRO-000064 (SZC- 100207813) or parts of the aforesaid quality management arrangements as ONR may specify.

17(4) The licensee shall ensure that once Finance Director None approved no alteration or amendment is made to the approved management Control Regulatory Approved Management Arrangements systems or approved quality NNB-102-PRO-000064 (SZC- 100207813) management arrangements unless ONR has approved the alteration or amendment.

17(5) The licensee shall furnish to ONR such Finance Director None Manage Interfaces with Regulators copies of records or documents made in

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connection with the aforesaid quality NNB-209-PRO-000026 (SZC- 100207786) management arrangements as ONR (Manage Incoming Regulatory Correspondence and Notifications) may specify. (Manage Outgoing Regulatory Correspondence)

Licence Condition 18 – Radiological Protection

Arrangements for Compliance Person Responsible for LC Licence Condition Compliance Comments Non-Active Active Commissioning Pre-FID Phase Construction Phase Operation Phase Decommissioning Phase Arrangements Commissioning Phase Phase

18(1) The licensee shall make and implement Safety, Licencing and Arrangements will be implemented to Review Radiation Exposure adequate arrangements for the assessment of Assurance Director classify persons and assess, record the average effective dose equivalent and report on, their exposure to NNB-308-PRO-000003 (Engineering and Delivery (including any committed effective dose radiation. N/A Event Categorisation, Offsite Reporting and equivalent) to such class or classes of persons Director SZC) Notification as may be specified in the aforesaid The Radiological Safety Standard (no Site Ownership) arrangement is primarily needed for arrangements and the licensee shall forthwith NNB-308-GUI-000082 notify ONR if the average effective dose compliance with the Ionising Arrangement: Radiological Protection Safety Rules (Incorporating equivalent to such class or classes of persons Radiation Regulations (2017). (Only when First Sources arrive on site) Classification of Workers) exceeds such level as ONR may specify.

Radiological Safety Standard N/A HPC-NNBGEN-XX-000-STA-100016 (no Site Ownership) (Only when first sources arrive on site)

Manage Interfaces with Regulators

NNB-209-PRO-000026 (SZC- 100207786) -(Manage Incoming Regulatory Correspondence and Notifications)

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Licence Condition 18 – Radiological Protection

18(2) The licensee shall submit to ONR for approval Safety, Licencing and None such part or parts of the aforesaid Assurance Director Control Regulatory Approved Management Arrangements arrangements as ONR may specify. (Engineering and Delivery NNB-102-PRO-000064 (SZC- 100207813) Director SZC)

18(3) The licensee shall ensure that once approved Safety, Licencing and None no alteration or amendment is made to the Assurance Director Control Regulatory Approved Management Arrangements approved arrangements unless ONR has approved such alteration or amendment. (Engineering and Delivery NNB-102-PRO-000064 (SZC- 100207813) Director SZC)

Licence Condition 19 – Construction or Installation of New Plant

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Licence Condition 19 – Construction or Installation of New Plant

19(1) Where the licensee proposes to construct or Engineering and The construction or installation of install any new plant which may affect safety Delivery Director new plant is monitored using site SZC Equivalents of : the licensee shall make and implement surveillance processes. adequate arrangements to control the Manage Site Surveillance construction or installation. A suite of procedures is available for managing construction change, NNB-205-PRO-000089 including field change requests. Ensure Safe Control of Work Activities Construction documentation is controlled in accordance with the NNB-308-PRO-000082 appropriate company procedure. Request For Information Hold points will be attached to NNB-201-PRO-000030 construction activities as Early works (e.g. Ground appropriate. Manage Construction Change – Field Change Request Investigation.) prior The arrangements will include to licencing covered NNB-205-PRO-000110 appropriate liaison with the by CDM licensee of the adjacent site to requirements- Control Construction Documents manage the impact of construction (Construction Phase NNB-301-PRO-000018 or installation upon the safety and Plan and associated security of the adjacent facility. processes.) Define, Manage and Release Key Hold Points

Procedures will be in place prior to NNB-209-PRO-000025 ( work commencing on site in the early construction phase. Communicate with Adjacent Facilities

NNB-209-PRO-000014

Manage Contractor Site Non-Conformance

NNB-205-PRO-000111

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Licence Condition 19 – Construction or Installation of New Plant

19(2) The licensee shall submit to ONR for Engineering and None approval such part or parts of the aforesaid Delivery Director Control Regulatory Approved Management Arrangements arrangements as ONR may specify NNB-102-PRO-000064 (SZC- 100207813)

19(3) The licensee shall ensure that once approved Engineering and None no alteration or amendment is made to the Delivery Director Control Regulatory Approved Management Arrangements approved arrangements unless ONR has NNB-102-PRO-000064 (SZC- 100207813) approved such alteration or amendment

19(4) The aforesaid arrangements shall where Engineering and Construction will be divided into appropriate divide the construction or Delivery Director stages as appropriate. installation into stages. Where ONR so specifies the licensee shall not commence Hold points, some of which may Define, Manage and Release Key Hold Points nor thereafter proceed from one stage to the require regulatory consent to NNB-209-PRO-000025 next of the construction or installation proceed from, shall be attached to these stages to control progress. Shadow Working in without the consent of ONR. The Manage Safety Reports arrangements shall include a requirement for operation. Safety documentation, both the the provision of adequate documentation to NNB-202-PRO-000005 relevant Safety Report and justify the safety of the proposed Construction Safety Justification, construction or installation and shall where Manage Interfaces with Regulators shall be developed and submitted appropriate provide for the submission of where required to support the NNB-209-PRO-000026 (SZC- 100207786) this documentation to ONR release of hold points.

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Licence Condition 19 – Construction or Installation of New Plant

N/A no construction SZC equivalent of: commenced Manage Construction Safety Justifications

NNB-202-PRO-000016

19(5) The licensee shall, if so directed by ONR, halt Engineering and A direction from ONR is processed Manage Interfaces with Regulators - NNB-209-PRO-000026 (SZC- 100207786) the construction or installation of a plant and Delivery Director using the Regulatory Interface Early works prior to the licensee shall not recommence such Procedure. The instruction is licencing covered by Ensure Safe Control of Work Activities - NNB-308-PRO-000082 construction or installation without the implemented using the Hold CDM requirements- (Suspend / Transfer Work Authorisation & Permit For Work) consent of ONR. Points procedure. (Construction Phase Plan and associated Define, Manage and Release Key Hold Points processes.) NNB-209-PRO-000025

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Licence Condition 20 – Modification to Design of Plant Under Construction

20(1) The licensee shall ensure that no modification to the Engineering and Design modifications are design which may affect safety is made to any plant Delivery Director assessed for impact on Control Modifications During Construction and Commissioning during the period of construction except in accordance safety, categorised and with adequate arrangements made and implemented managed appropriately. NNB-202-PRO-000004 by the licensee for that purpose.

20(2) The licensee shall submit to ONR for approval such Engineering and None Control Regulatory Approved Management Arrangements part or parts of the aforesaid arrangements as ONR Delivery Director may specify. NNB-102-PRO-000064 (SZC- 100207813)

20(3) The licensee shall ensure that once approved no Engineering and None alteration or amendment is made to the approved Delivery Director Control Regulatory Approved Management Arrangements arrangements unless ONR has approved such NNB-102-PRO-000064 (SZC- 100207813) alteration or amendment.

20(4) The aforesaid arrangements shall provide for the Engineering and The Manage Design Change Manage Design Change (no Change Committee)- NNB-202-PRO-000033 classification of modifications according to their safety Delivery Director procedure and the significance. The arrangements shall where accompanying guidance Modification Categorisation and Preparation of the UK Context Annex-NNB-205-GUI-000008 appropriate divide modifications into stages. Where document define the safety Manage Interfaces with Regulartors- NNB-209-PRO-000026 (SZC- 100207786) ONR so specifies the licensee shall not commence nor categorisation and the

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thereafter proceed from one stage to the next of the environmental ranking of modification without the consent of ONR. The the modifications and the arrangements shall include a requirement for the safety documentation and provision of adequate documentation to justify the the submission route(s) Control Modifications During Construction and Commissioning- NNB-202-PRO-000004 safety of the proposed modification and shall, where required to justify each. appropriate provide for the submission of this Manage Interfaces with Regulartors-NNB-209-PRO-000026 (SZC- 100207786) documentation to ONR.

Licence Condition 21 – Commissioning

21(1) The licensee shall make and implement Engineering and Commissioning arrangements will be adequate arrangements for the Delivery Director implemented at Non-Active N/A Arrangement: Commissioning Manual commissioning of any plant or process (SZC) Commissioning. which may affect safety.

21(2) The licensee shall submit to ONR for Engineering and None approval such part or parts of the Delivery Director Control Regulatory Approved Management Arrangements N/A aforesaid arrangements as ONR may (SZC) NNB-102-PRO-000064 (SZC- 100207813) specify.

21(3) The licensee shall ensure that once (Engineering and None approved no alteration or amendment is Delivery Director Control Regulatory Approved Management Arrangements made to the approved arrangements SZC) N/A unless ONR has approved such NNB-102-PRO-000064 (SZC- 100207813) alteration or amendment.

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Licence Condition 21 – Commissioning

21(4) The aforesaid arrangements shall where Engineering and Procedures will be established to: appropriate divide the commissioning Delivery Director into stages. Where ONR so specifies the  Classify proposed commissioning licensee shall not commence nor (Engineering and affecting safety according to its thereafter proceed from one stage to Delivery Director nuclear safety significance Arrangement: Commissioning Manual the next of the commissioning without SZC)  Prepare and assess a safety case, in accordance with LC 14, for each the consent of ONR. The arrangements Define, Manage and Release Key Hold Points- NNB-209-PRO-000025 shall include a requirement for the proposed commissioning activity provision of adequate documentation to  Ensure proposals are not implemented N/A Manage Safety Reports- NNB-202-PRO-000005 justify the safety of the proposed until the appropriate clearances are commissioning and shall where obtained Manage Interfaces with Regulators- NNB-209-PRO-000026 (SZC- 100207786)  Divide, where appropriate, appropriate provide for the submission of this documentation to ONR. commissioning into stages  Ensure, where specified by the ONR, no stage proceeds without consent  Submit, where appropriate, the safety documentation to the ONR

21(5) The licensee shall appoint a suitably Engineering and Persons managing, undertaking or qualified person or persons for the Delivery Director witnessing commissioning activities will be Management of Competency purpose of controlling, witnessing, properly trained and be competent to do (Engineering and N/A recording and assessing the results of so, with competency requirements set out NNB-207-PRO-000002_SZC/ 100207760- Arrangement: Manage Authorisations any tests carried out in accordance with Delivery Director in the Commissioning Manual. Training the requirements of the aforesaid will be compliant with arrangements for

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Licence Condition 21 – Commissioning

Arrangements for Compliance Person Responsible for Non-Active Active LC Licence Condition Comments Decommissioning Compliance Pre-FID Phase Construction Phase Commissioning Commissioning Operation Phase Phase Arrangements Phase Phase commissioning arrangements SZC) LC 10, and will be provided to ensure persons are Suitably Qualified and Experienced as per arrangements for LC 12. Arrangement: Handover from N/A Commissioning to Operations

21(6) The licensee shall ensure that full and Engineering and Arrangements developed under LC 6 for accurate records are kept of the results Delivery Director records production and retention shall be of every test and operation carried out referenced and utilised by LC 21 in pursuance of this condition (Engineering and arrangements to ensure full and accurate Documents and Records Code of Practice- NNB-301-COP-000001 N/A Delivery Director records are kept of the results of every High Level Records Retention Schedule- NNB-301-STR-000010 SZC) test and operation carried out during the commissioning of new plant which affects safety

21(7) The licensee shall ensure that no plant Engineering and None or process which may affect safety is Delivery Director operated (except for the purpose of Arrangement: Commissioning Manual commissioning) until: (Engineering and Delivery Director N/A Define, Manage and Release Key Hold Points- NNB-209-PRO-000025 (a) the appropriate stage of SZC) commissioning has been completed and Manage Safety Reports- NNB-202-PRO-000005 a report of such commissioning, including any results and assessments of any tests as may have been required

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Licence Condition 21 – Commissioning

Arrangements for Compliance Person Responsible for Non-Active Active LC Licence Condition Comments Decommissioning Compliance Pre-FID Phase Construction Phase Commissioning Commissioning Operation Phase Phase Arrangements Phase Phase under the commissioning arrangements referred to in paragraph (1) of this condition, has been considered in accordance with those arrangements; and;

(b) a safety case or cases as appropriate, which shall include the safety implications of modifications made since Control Modifications During Construction the commencement of construction of N/A and Commissioning Arrangement: LC 22 the plant and those arising from the NNB-202-PRO-000004 commissioning of the plant, and any matters whereby the operation of the plant may be affected by such modifications or commissioning, has been considered in accordance with the arrangements referred to in paragraph (1) of this condition

21(8) The licensee shall, if so notified by ONR, Engineering and If so notified by the ONR, the safety case submit to ONR the safety case for the Delivery Director documentation shall be submitted to the aforesaid plant or processes prepared in ONR. Manage Safety Reports-NNB-202-PRO-000005 pursuance of paragraph (7) of this (Engineering and Delivery Director A hold point will be applied to the start of condition and shall not commence N/A Define, Manage and Release Key Hold Points- NNB-209-PRO-000025 operation of the relevant plant or SZC) operation of the plant. process without the consent of ONR Manage Interfaces with Regulators- NNB-209-PRO-000026 (SZC- 100207786)

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Licence Condition 22 – Modification or Experiment on Existing Plant

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Licence Condition 22 – Modification or Experiment on Existing Plant

22(1) The licensee shall make and implement adequate Engineering and None N/A arrangements to control any modification or Delivery Director experiment carried out on any part of the existing plant or processes which may affect safety.

Arrangements: LC 22

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Licence Condition 22 – Modification or Experiment on Existing Plant

22(2) The licensee shall submit to ONR for approval such Engineering and None N/A part or parts of the aforesaid arrangements as ONR Delivery Director may specify.

Control Regulatory Approved Management Arrangements

NNB-102-PRO-000064 (SZC- 100207813)

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Licence Condition 22 – Modification or Experiment on Existing Plant

22(3) The licensee shall ensure that once approved no Engineering and None N/A alteration or amendment is made to the approved Delivery Director arrangements unless ONR has approved such alteration or amendment.

Control Regulatory Approved Management Arrangements

NNB-102-PRO-000064 (SZC- 100207813)

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Licence Condition 22 – Modification or Experiment on Existing Plant

22(4) The aforesaid arrangements shall provide for the Engineering and None classification of modifications or experiments Delivery Director according to their safety significance. The Arrangements: LC 22 arrangements shall where appropriate divide the Manage Interfaces with Regulators modification or experiment into stages. Where ONR so specifies the licensee shall not commence nor NNB-209-PRO-000026 (SZC- 100207786) thereafter proceed from one stage to the next of the N/A modification without the consent of ONR. The (Manage Incoming Regulatory arrangements shall include a requirement for the Correspondence and Notifications) provision of adequate documentation to justify the (Manage Outgoing Regulatory safety of the proposed modification or experiment Correspondence) and shall where appropriate provide for the submission of the documentation to ONR.

22(5) The licensee shall, if so directed by ONR, halt the Engineering and None Manage Interfaces with Regulators modification or experiment and the licensee shall Delivery Director not recommence such modification or experiment NNB-209-PRO-000026 (SZC- 100207786) without the consent of ONR (Manage Incoming Regulatory Correspondence and Notifications)

(Manage Outgoing Regulatory Correspondence)

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Licence Condition 23 – Operating Rules

23(1) The licensee shall, in respect of any Safety, operation that may affect safety, produce Licencing and Safety reports will identify operations an adequate safety case to demonstrate Assurance that may affect safety. the safety of that operation and to Safety reports will also demonstrate Director Manage Safety Reports identify the conditions and limits the safety of the identified operations. Shadow Working Technical Specifications: UK EPR necessary in the interests of safety. Such (Pre NNB-202-PRO-000005 The conditions and limits arising from Arrangement: Use and Application of Technical Specifications conditions and limits shall hereinafter be Operations the safety reports will be applied referred to as operating rules. Director when through Operating Rules or Technical appointed) Specifications.

23(2) The licensee, where ONR so specifies, Safety, shall refer the operating rules arising Licencing and Technical Specifications: UK EPR from paragraph (1) of this condition to Assurance Preparation, alteration and Arrangement: Use and Application of Technical Specifications the relevant nuclear safety committee Director for consideration. amendment of the Operating Rules or (Pre Technical Specifications will be N/A Manage Interfaces with Regulators Operations progressed as a modification, and will Director when be considered by the NSC. NNB-209-PRO-000026 (SZC- 100207786) appointed) (Manage Incoming Regulatory Correspondence and Notifications)

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Licence Condition 23 – Operating Rules

23(3) The licensee shall ensure that operations Safety, Operations will be undertaken in are at all times controlled and carried out Licencing and adherence to Operating Rules or Develop Role And Training Profiles in compliance with such operating rules. Assurance Technical Specifications. Where the person appointed by the Director NNB-207-PRO-000002_SZC/ 100207760 licensee for the purposes of Condition 26

identifies any matter indicating that the (Pre Competent personnel will be identified safety of any operation or the safe Operations and appointed to control operations in accordance with Operating Rules. condition of any plant may be affected Director when Assess Individual Competency that person shall bring that matter to the appointed) N/A attention of the licensee forthwith who NNB-102-PRO-000111_SZC/ 100207753 In the event of any indication that a shall take appropriate action and ensure plant item or operation is outside the the matter is then notified, recorded, conditions and limits specified in the investigated and reported in accordance Operating Rules or Technical with arrangements made under Condition Technical Specifications: UK EPR Specifications defined in LC 23(1), the 7. plant will be restored to a state within Arrangement: Use and Application of Technical Specifications the conditions and limits.

If any circumstances arise which suggest that the Operating Rules or Technical Specifications defined in LC 23(1) do not provide an appropriate level of safety, an operating Technical Specifications: UK EPR N/A instruction will be issued defining Arrangement: Use and Application of Technical Specifications operational limitations which will be sufficient to ensure safety. A report shall be submitted to the subsequent NSC meeting.

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Licence Condition 23 – Operating Rules

Notification, recording, investigation and reporting of events are initiated by the competent person controlling Enable Organisational Learning and supervising the operation of the N/A NNB-104-PRO-000011_SZC/ 100208059 plant in accordance with LC 26 and is carried out in accordance with the requirements of LC 7.

23(4) The licensee shall submit to ONR for Safety, Licencing None approval such of the aforesaid operating and Assurance Control Regulatory Approved Management Arrangements rules as ONR may specify. Director N/A NNB-102-PRO-000064 (SZC- 100207813)

(Pre-Ops Director)

23(5) The licensee shall ensure that once Safety, Licencing None approved no alteration or amendment is and Assurance Control Regulatory Approved Management Arrangements made to any approved operating rule Director N/A NNB-102-PRO-000064 (SZC- 100207813) unless ONR has approved such alteration or amendment. (Pre-Ops Director)

23(6) Notwithstanding the preceding provisions Safety, Licencing None of this condition ONR may, if in its opinion and Assurance circumstances render it necessary at any Director N/A Arrangement: Suspension of Technical Specifications time, agree to the temporary suspension of any approved operating rule. (Pre-Ops Director)

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Licence Condition 24 – Operating Instructions

24(1) The licensee shall ensure that all operations Pre-Ops Director Operations will be undertaken Appropriate which may affect safety are carried out in using work instructions generated measures for accordance with written instructions under LC 24(4) setting plant to Work Instructions: Operation hereinafter referred to as operating N/A work will be instructions. covered in Arrangement: Generating, Using and Reviewing Operating Instructions construction processes.

24(2) The licensee shall ensure that such operating Safety, Licencing Operating instructions include the Appropriate instructions include any instructions necessary and Assurance necessary prerequisites, measures for in the interests of safety and any instructions Director precautions, conditions, limits and setting plant to Arrangement: Operating Instructions necessary to ensure that any operating rules actions to be taken in the interests (Pre-Ops N/A work will be Arrangement: Temporary Operating Instructions are implemented. of safety and to implement the Director) covered in Operating Rules and Operating Arrangement: Generating, Using and Reviewing Operating Instructions construction Instructions or Technical processes. Specifications.

24(3) The licensee shall, if so specified by ONR, Safety, Licencing None furnish to ONR copies of such operating and Assurance Manage Interfaces with Regulators instructions and when any alteration is made Director NNB-209-PRO-000026 (SZC- 100207786) to the operating instructions furnished to N/A (Pre-Ops (Manage Incoming Regulatory Correspondence and Notifications) ONR, the licensee shall ensure that such Director) alteration is furnished to ONR within such time (Manage Outgoing Regulatory Correspondence) as may be specified.

24(4) The licensee shall make and implement Safety, Licencing None adequate arrangements for the preparation, and Assurance Arrangement: Operating Instructions review and amendment of such operating Director N/A Arrangement: Generating, Using and Reviewing Operating Instructions instructions. (Pre-Ops Director)

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Licence Condition 24 – Operating Instructions

24(5) The licensee shall submit to ONR for approval Safety, Licencing None such part or parts of the aforesaid and Assurance Control Regulatory Approved Management Arrangements arrangements as ONR may specify. Director N/A NNB-102-PRO-000064 (SZC- 100207813) (Pre-Ops Director)

24(6) The licensee shall ensure that once approved Safety, Licencing None no alteration or amendment is made to the and Assurance Control Regulatory Approved Management Arrangements approved arrangements unless ONR has Director N/A NNB-102-PRO-000064 (SZC- 100207813) approved such alteration or amendment. (Pre-Ops Director)

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Licence Condition 25 – Operational Records

Arrangements for Compliance

Person Responsible for Non-Active Active LC Licence Condition Comments Decommissioning Compliance Arrangements Pre-FID Phase Construction Phase Commissioning Commissioning Operation Phase Phase Phase Phase

25(1) The licensee shall ensure that Safety, Licencing and The Record Retention Schedule Records of EMITS adequate records are made of the Assurance Director will be updated to include Records of Documents and Records Code of Practice carried out to operation, inspection and maintenance (Pre-Ops Director) operations, maintenance and preservation and preserve nuclear NNB-301-COP-000001 of any plant which may affect safety. inspection. N/A any routine safety capability preservation High Level Records Retention Schedule during maintenance NNB-301-STR-000010 commissioning.

25(2) The aforesaid records shall include Safety, Licencing and None records of the amount and location of Assurance Director Documents and Records Code of Practice all radioactive material, including (Pre-Ops Director) NNB-301-COP-000001 nuclear fuel and radioactive waste, N/A used, processed, stored or High Level Records Retention Schedule accumulated upon the site at any time. NNB-301-STR-000010

25(3) The licensee shall record such Safety, Licencing and None additional particulars as ONR may Assurance Director Records of EMITS Records of Documents and Records Code of Practice- NNB-301-COP-000001 specify. carried out to (Pre-Ops Director) preservation and preserve nuclear Manage Interfaces with Regulators N/A any routine safety capability preservation NNB-209-PRO-000026 (SZC- 100207786) during maintenance (Manage Incoming Regulatory Correspondence and Notifications) commissioning.

25(4) The licensee shall furnish to ONR such Safety, Licencing and None Records of EMITS Records of Manage Interfaces with Regulators copies of extracts from such records at Assurance Director carried out to preservation and such times as ONR may specify. preserve nuclear NNB-209-PRO-000026 (SZC- 100207786) (Pre-Ops Director) N/A any routine safety capability preservation (Manage Incoming Regulatory Correspondence and Notifications) during maintenance (Manage Outgoing Regulatory Correspondence) commissioning.

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Licence Condition 26 – Control and Supervision of Operations

26 The licensee shall ensure that no Safety, Licencing Arrangements for the identification and Develop Role And Training Profiles operations are carried out which may and Assurance notification of DAPs will be in place for the NNB-207-PRO-000002_SZC/ 100207760 affect safety except under the control Director start of the Non-Active Commissioning

and supervision of suitably qualified (Pre-Ops Director) phase. N/A and experienced persons appointed for The Management of Roles and Assess Individual Competency that purpose by the licensee Competencies arrangements will be NNB-102-PRO-000111_SZC/ 100207753 reviewed prior to the start of the Active

Commissioning phase to reflect the appointment of DAPs.

Arrangement: Manage Authorisations N/A Arrangement: Management of Operational Competency

N/A Arrangement: Control of Work

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Licence Condition 27 – Safety Mechanisms, Devices and Circuits

27 The licensee shall ensure that a Safety, Licencing and The safety case for the UK-EPR will plant is not operated, inspected, Assurance Director describe the safety mechanisms, devices maintained or tested unless suitable and circuits. It will also identify the plant When Installed and sufficient safety mechanisms, (Pre-Ops Director) that is required to be properly connected Manage Safety Reports Control Maintenance of Installed Plant and devices and circuits are properly and in good working order in the relevant N/A NNB-202-PRO-000005 Equipment connected and in good working plant operating states. EMITS process. (TBA) order. NNB-205-PRO-000115

Safety, Licencing and Operating Rules and Operating When Installed Assurance Director Instructions will be implemented, describing the requirements of the safety Control Maintenance of Installed Plant and Arrangement: Operating Rules (LC 23) (Pre-Ops Director) N/A case. Equipment Arrangement: Operating Instructions (LC 24) NNB-205-PRO-000115

Arrangements will be implemented to When Installed ensure safety mechanisms, devices and Control Maintenance of Installed Plant and circuits are connected and in good N/A Arrangement: Maintenance working order. Equipment NNB-205-PRO-000115

SQEPs will control the release and re- instatement of such plant in accordance When Installed with the Operating Rules and Operating Control Maintenance of Installed Plant and N/A Arrangement: Work Control Process Instructions Equipment NNB-205-PRO-000115

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Licence Condition 28 – Examination, Inspection, Maintenance and Testing

Arrangements for Compliance Person Responsible Non-Active Active LC Licence Condition for Compliance Comments Pre- FID Construction Decommissioning Commissioning Commissioning Operation Phase Arrangements Phase Phase Phase Phase Phase

28(1) The licensee shall make and implement Safety, Licencing and EIMT arrangements will be When installed adequate arrangements, for the regular Assurance Director implemented for all plant that may Control Maintenance of Installed Plant and and systematic examination, inspection, affect safety, including early takeover N/A Arrangement: Maintenance (Pre-Ops Director) Equipment maintenance and testing of all plant plant. which may affect safety. NNB-205-PRO-000115

28(2) The licensee shall submit to ONR for Safety, Licencing and None approval such part or parts of the Assurance Director Control Regulatory Approved Management Arrangements N/A aforesaid arrangements as ONR may (Pre-Ops Director) NNB-102-PRO-000064 (SZC- 100207813) specify.

28(3) The licensee shall ensure that once Safety, Licencing and None approved no alteration or amendment is Assurance Director Control Regulatory Approved Management Arrangements made to the approved arrangements (Pre-Ops Director) N/A unless ONR has approved such alteration NNB-102-PRO-000064 (SZC- 100207813) or amendment.

28(4) The aforesaid arrangements shall provide Safety, Licencing and A maintenance schedule will be for the preparation of a plant Assurance Director produced. The format of the When installed maintenance schedule for each plant. The maintenance schedule will be the (Pre-Ops Director) Control Maintenance of Installed Plant and Schedule: Maintenance licensee shall submit to ONR for its subject of further discussion with N/A Equipment Arrangement: Maintenance approval such part or parts of any plant ONR maintenance schedule as ONR may NNB-205-PRO-000115 specify. Safety, Licencing and None When installed Assurance Director Control Maintenance of Installed Plant and Control Regulatory Approved Management Arrangements N/A (Pre-Ops Director) Equipment NNB-102-PRO-000064 (SZC- 100207813) NNB-205-PRO-000115

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Licence Condition 28 – Examination, Inspection, Maintenance and Testing

28(5) The licensee shall ensure that once Safety, Licencing and None When installed approved no alteration or amendment is Assurance Director Control Maintenance of Installed Plant and Control Regulatory Approved Management Arrangements made to any approved part of any plant N/A (Pre-Ops Director) Equipment maintenance schedule unless ONR has NNB-102-PRO-000064 (SZC- 100207813) approved such alteration or amendment. NNB-205-PRO-000115

28(6) The licensee shall ensure in the interests Safety, Licencing and None When installed of safety that every examination, Assurance Director Control Maintenance of Installed Plant and N/A inspection, maintenance and test of a (Pre-Ops Director) Equipment plant or any part thereof is carried out: NNB-205-PRO-000115

By suitably qualified and experienced Safety, Licencing and EIMT will be undertaken by SQEPs. Competent maintenance skills Competent maintenance skills persons; Assurance Director for plant preservation when installed Develop Role And Training Profiles (Pre-Ops Director) Develop Role And Training Profiles N/A NNB-207-PRO-000002_(SZC/ 100207760) NNB-207-PRO-000002_(SZC/ 100207760) Assess Individual Competency Assess Individual Competency NNB-102-PRO-000111_SZC/ 100207753 NNB-102-PRO-000111_SZC/ 100207753

In accordance with schemes laid down in Safety, Licencing and None When installed writing; Assurance Director Control Maintenance of Installed Plant and N/A Instructions: EIMT (Pre-Ops Director) Equipment NNB-205-PRO-000115

Within the intervals specified in the plant Safety, Licencing and The plant maintenance schedule will When installed maintenance schedule; and Assurance Director define the intervals in which EIMT is Control Maintenance of Installed Plant and N/A Schedule: Maintenance (Pre-Ops Director) undertaken. Equipment NNB-205-PRO-000115

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Licence Condition 28 – Examination, Inspection, Maintenance and Testing

Under the control and supervision of a Safety, Licencing and EIMT will be supervised by SQEPs. suitably qualified and experienced person Assurance Director Develop Role And Training Profiles- NNB-207-PRO-000002_SZC/ 100207760 N/A appointed by the licensee for that (Pre-Ops Director) Assess Individual Competency- NNB-102-PRO-000111_SZC/ 100207753 purpose.

28(7) Notwithstanding the above paragraphs of Safety, Licencing and The arrangements will provide for Control this condition ONR may agree to an Assurance Director the extension of any interval Modifications extension of any interval specified in the specified in the maintenance Modification process for care and During Construction (Pre-Ops Director) N/A Arrangements: LC22 plant maintenance schedule. schedule, and will include the maintenance regime. and Commissioning provision to seek the agreement of NNB-202-PRO- ONR where required. 000004

28(8) When any examination, inspection, Safety, Licencing and NNB GenCo (SZC) will ensure that maintenance or test of any part of a plant Assurance Director any matter identified by EIMT which When installed reveals any matter indicating that the safe (Pre-Ops Director) may affect the safe condition or N/A. Control Maintenance of Installed Plant and Arrangement: Maintenance operation or safe condition of that plant operation of the plant is reported to Equipment-NNB-205-PRO-000115 may be affected, the suitably qualified the licensee. and experienced person appointed to control or supervise any such NNB GenCo (SZC) will ensure that any matter described above is examination, inspection, maintenance or When installed Enable Organisational Learning test shall bring it to the attention of the notified, recorded, investigated and N/A. Control Maintenance of Installed Plant and NNB-104-PRO-000011_SZC/ 100208059 licensee forthwith who shall take reported in accordance with LC7 Equipment-NNB-205-PRO-000115 appropriate action and ensure the matter is then notified, recorded, investigated and reported in accordance with arrangements made under Condition 7. NNB GenCo (SZC) will ensure that When installed any required remedial action is taken N/A. Control Maintenance of Installed Plant and Arrangement: Maintenance to ensure safety Equipment-NNB-205-PRO-000115

If appropriate, any relevant Safety When installed Case will be reviewed. N/A. Control Maintenance of Installed Plant and Arrangements: LC22 Equipment-NNB-205-PRO-000115

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Licence Condition 28 – Examination, Inspection, Maintenance and Testing

28(9) The licensee shall ensure that a full and Safety, Licencing and NNB GenCo (SZC) will ensure that accurate report of every examination, Assurance Director appropriate reports are produced by When installed inspection, maintenance or test of any (Pre-Ops Director) the person(s) appointed to control or N/A. Control Maintenance of Installed Plant and Arrangement: Maintenance part of a plant indicating the date thereof supervise EIMT. Equipment-NNB-205-PRO-000115 and signed by the suitably qualified and experienced person appointed by the licensee to control and supervise such Appropriate records of EIMT will be When installed kept examination, inspection, maintenance or Control Maintenance of Installed Plant and Documents and Records Code of Practice test is made to the licensee forthwith N/A Equipment-NNB-205-PRO-000115 NNB-301-COP-000001 upon completion of the said examination, inspection, maintenance or test. Documents and Records Code of Practice NNB-301-COP-000001

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Licence Condition 29 – Duty to Carry Out Tests, Inspections and Examinations

Arrangements for Compliance Person Responsible for Non-Active Active LC Licence Condition Compliance Comments Decommissioning Pre-FID Phase Construction Phase Commissioning Commissioning Operation Phase Arrangements Phase Phase Phase

29(1) The licensee shall carry out such tests, Safety, Licencing and None inspections and examinations in connection Assurance Director with any plant (in addition to any carried out When installed Arrangement: Maintenance under Condition 28 above) as ONR may, after (Pre-Ops Director) Control Maintenance of Installed Plant and consultation with the licensee, specify. N/A Equipment Manage Interfaces with Regulators NNB-205-PRO-000115 NNB-209-PRO-000026 (SZC- 100207786) (Manage Incoming Regulatory Correspondence and Notifications)

29(2) The licensee shall furnish the results of any Safety, Licencing and None such tests, inspections and examinations Assurance Director carried out in accordance with paragraph (1) When installed Arrangement: Maintenance of this condition to ONR as soon as (Pre-Ops Director) Control Maintenance of Installed Plant and Manage Interfaces with Regulators practicable. N/A. Equipment NNB-205-PRO-000115 NNB-209-PRO-000026 (SZC- 100207786) (Manage Outgoing Regulatory Correspondence)

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Licence Condition 30 – Periodic Shutdown

30(1) When necessary for the purpose of Safety, Licencing and None enabling any examination, inspection, Assurance Director When installed maintenance or testing of any plant or (Pre-Ops Director) Control Maintenance of Installed Plant and Schedule: Maintenance process to take place, the licensee shall N/A ensure that any such plant or process shall Equipment Arrangement: Maintenance be shut down in accordance with the NNB-205-PRO-000115 requirements of its plant maintenance schedule referred to in Condition 28. None N/A Strategy: Outage

30(2) Notwithstanding paragraph (1) of this Safety, Licencing and No arrangements are required condition ONR may agree to an extension Assurance Director under LC30(2) of a plant’s operating period. N/A (Pre-Ops Director)

30(3) The licensee shall, if so specified by ONR, Safety, Licencing and None Define, Manage and Release Key Hold Points procedure ensure that when a plant or process is shut Assurance Director NNB-209-PRO-000025 down in pursuance of paragraph (1) of this condition it shall not be started up again (Pre-Ops Director) N/A thereafter without the consent of ONR. Manage Interfaces with Regulators

NNB-209-PRO-000026 (SZC- 100207786) (Manage Incoming Regulatory Correspondence and Notifications)

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Licence Condition 31 – Shutdown of Specified Operations

31(1) The licensee shall, if so directed by ONR, shut Safety, Licencing and None down any plant, operation or process on the Assurance Director site within such period as ONR may specify. (Pre-Ops Director) Arrangement: LC 31

Manage Interfaces with Regulators N/A NNB-209-PRO-000026 (SZC- 100207786) (Manage Incoming Regulatory Correspondence and Notifications)

31(2) The licensee shall ensure that when a plant, Safety, Licencing and None operation or process is shut down in Assurance Director pursuance of paragraph (1) of this condition it Arrangement: LC 31 (Pre-Ops Director) shall not be started up again thereafter Manage Interfaces with Regulators without the consent of ONR. N/A NNB-209-PRO-000026 (SZC- 100207786) (Manage Incoming Regulatory Correspondence and Notifications)

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Licence Condition 32 – Accumulation of Radioactive Waste

32(1) The licensee shall make and Safety, Licencing A process exists for NNB GenCo (SZC) to review the implement adequate and Assurance risks associated with radioactively contaminated arrangements for minimising so Director land or groundwater which may be encountered Control of Contaminated Land and Groundwater far as is reasonably practicable (Pre-Ops during excavation work, and to develop a NNB-306-PRO-000036 (SZC/ 100232600) the rate of production and total management plan if contamination is detected. The Director) N/A Manage Safety Reports- NNB-202-PRO-000005 quantity of radioactive waste process will minimise the production of any accumulated on the site at any radioactive waste and will minimise the quantity of Integrated Waste Strategy- (NNB-209-STR-000045) time and for recording the any radioactive waste accumulated on site. Manage Environment Case - (NNB-209-PRO-000032 (SZC/ 100232424) waste so accumulated. The compliance arrangements for Licence Condition 14(1) cover the development of safety cases for the accumulation of radioactive waste in radioactive waste storage buildings during operation. Further LC32 arrangements will be implemented at N/A Arrangements: LC32 Radioactive Commissioning.

32(2) The licensee shall submit to Safety, Licencing None ONR for approval such part or and Assurance Control Regulatory Approved Management Arrangements parts of the aforesaid Director NNB-102-PRO-000064 (SZC- 100207813) arrangements as ONR may (Pre-Ops specify. Director)

32(3) The licensee shall ensure that Safety, Licencing None once approved no alteration or and Assurance amendment is made to the Director Control Regulatory Approved Management Arrangements approved arrangements unless (Pre-Ops NNB-102-PRO-000064 (SZC- 100207813) ONR has approved such Director) alteration or amendment.

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Licence Condition 32 – Accumulation of Radioactive Waste

32(4) Without prejudice to paragraph Safety, Licencing Radioactive waste that might be accumulated on (1) of this condition the licensee and Assurance site by the management of radioactively shall ensure that radioactive Director contaminated land or groundwater will comply with waste accumulated or stored on (Pre-Ops any limits on quantity, type and form specified by the site complies with such Director) ONR. These limits would be contained within the limitations as to quantity, type relevant management plan. and form as may be specified by For the accumulation of radioactive waste in Manage Interfaces with Regulators - NNB-209-PRO-000026 (SZC- 100207786) ONR. radioactive waste storage buildings during operation, any specification from ONR will be contained within the relevant safety case and will be covered by the compliance arrangements for LC 14(1).

32(5) The licensee shall, if so specified Safety, Licencing If radioactive waste is produced from the by ONR, not accumulate and Assurance management of radioactively contaminated land, radioactive waste except in a Director NNB GenCo (SZC) will ensure the management plan place and in a manner approved (Pre-Ops developed from the Contaminated Land Procedure by ONR. Director) details the place and manner approved by ONR, if specified. Manage Interfaces with Regulators- NNB-209-PRO-000026 (SZC- 100207786)- For the accumulation of radioactive waste in radioactive waste storage buildings during operation, any specification from ONR will be contained within the relevant safety case and will be covered by the compliance arrangements for LC 14(1).

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Licence Condition 33 – Disposal of Radioactive Waste

33 The licensee shall, if so Safety, Licencing If directed by the ONR, NNB GenCo (SZC) would directed by ONR, ensure that and Assurance dispose of any radioactive waste generated from the radioactive waste Director management of radioactively contaminated land as accumulated or stored on the (Pre-Ops Director) specified by ONR. The disposal route would be via site is disposed of as ONR may an exemption provision in the Environmental specify and in accordance with Permitting (England and Wales) (Amendment) an environmental permit, or Regulations 2016 or in accordance with a an existing permit which has Radioactive Substances Regulation (RSR) Procedures developed to manage waste streams. become an environmental environmental permit, and this route would be Manage Interfaces with Regulators Manage Interfaces with Regulators permit, granted under the described in the relevant management plan. Environmental Permitting NNB-209-PRO-000026 (SZC- 100207786) NNB-209-PRO-000026 (SZC- 100207786) (England and Wales) Regulations 2016.

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Licence Condition 34 – Leakage and Escape of Radioactive Material and Radioactive Waste

34(1) The licensee shall ensure, so far as Engineering and A Company Procedure is used to control the risks Fully developed arrangements. is reasonably practicable, that Delivery Director associated with radioactively contaminated land Control of Contaminated Land and Groundwater radioactive material and (Engineering and or groundwater which may be encountered Interim Control of Contaminated Land and radioactive waste on the site is at Delivery Director during excavation work, ensuring safe storage Groundwater NNB-306-PRO-000036 (SZC/ NNB-306-PRO-000036 (SZC/ 100232600) ) all times adequately controlled or SZC) and containment of any radioactive material prior 100232600) Manage Safety Reports contained so that it cannot leak or to disposal. Integrated Waste Strategy NNB-202-PRO-000005 otherwise escape from such (NNB-209-STR-000045) control or containment. Integrated Waste Strategy The compliance arrangements for Licence Manage Environment Case (NNB-209-STR-000045) Condition 14(1) cover the development of safety (NNB-209-PRO-000032_SZC/ 100232424) cases for systems and buildings that contain Manage Environment Case radioactive material or waste. (NNB-209-PRO-000032_SZC/ 100232424) Further LC34 arrangements will be implemented at Active Commissioning. N/A Arrangements: LC34

34(2) Notwithstanding paragraph (1) of Engineering and Control of Contaminated Land and Groundwater A Company Procedure is used to control the risks this condition the licensee shall Delivery Director associated with radioactively contaminated land NNB-306-PRO-000036_SZC/ 100232600 ensure, so far as is reasonably (Engineering and or groundwater which may be encountered practicable, that no such leak or Delivery Director Enable Organisational Learning during excavation work. A plan developed using escape of radioactive material or SZC) NNB-104-PRO-000011-_SZC/ 100208059 the procedure will include measures to prevent radioactive waste can occur and detect leakage. Integrated Waste Strategy without being detected, and that (NNB-209-STR-000045) any such leak or escape is then Any such leakage or escape of radioactive notified, recorded, investigated material will be notified, recorded, investigated Manage Environment Case and reported in accordance with and reported in accordance with arrangements (NNB-209-PRO-000032_SZC/ 100232424) arrangements made under made under Licence Condition 7. condition 7. Investigate Incidents Further LC34 arrangements will be implemented NNB-308-PRO-000040_SZC/ 100207765 at Active Commissioning. N/A Arrangements: LC 34

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Licence Condition 34 – Leakage and Escape of Radioactive Material and Radioactive Waste

34(3) Nothing in this condition shall Engineering and No arrangements are required under this LC apply to discharges or releases of Delivery Director clause. radioactive waste in accordance (Engineering and with an approved operating rule or Delivery Director environmental permit, or an SZC) N/A existing permit which has become an environmental permit, granted under the Environmental Permitting (England and Wales) Regulations 2016.

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Licence Condition 35 – Decommissioning

35(1) The licensee shall make and implement Engineering and Detailed Decommissioning and Waste Management Plan adequate arrangements for the Delivery Director NNB-209-REP-000644 decommissioning of any plant or process None N/A which may affect safety (NNB-PEA-REP-000002)

Engineering and Design changes are assessed for Control Modifications During Construction and Commissioning Delivery Director impacts on decommissioning. N/A NNB-202-PRO-000004 Arrangement: LC 22

Engineering and Station Decommissioning Committee Arrangement: Delivery Director Station N/A Decommissioning Committee Terms of Reference

Engineering and Decommissioning arrangements Delivery Director N/A Arrangement: LC 35

35(2) The licensee shall make arrangements for Engineering and The Detailed Decommissioning and Schedule attached to the Detailed Schedule attached to the Detailed Decommissioning and Waste the production and implementation of Delivery Director Waste Management Plan will include a Decommissioning and Waste Management Management Plan decommissioning programme for each schedule detailing content and Plan, including regulatory hold points N/A NNB-209-REP-000644 plant timescales of decommissioning NNB-209-REP-000644 activities. (NNB-PEA-REP-000002) (NNB-PEA-REP-000002)

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Licence Condition 35 – Decommissioning

35(3) The licensee shall submit to ONR for Engineering and Control Regulatory Approved Management Arrangements approval such part or parts of the aforesaid Delivery Director NNB-102-PRO-000064 (SZC- 100207813) arrangements or programmes as ONR may None N/A specify

The licensee shall ensure that once Engineering and 35(4) Control Regulatory Approved Management Arrangements approved no alteration or amendment is Delivery Director made to the approved arrangements or None N/A NNB-102-PRO-000064 (SZC- 100207813) programmes unless ONR has approved such alteration or amendment

35(5) The aforesaid arrangements shall where Safety, Licencing NNB GenCo (SZC) will develop a Detailed Decommissioning and Waste Management Plan appropriate divide the decommissioning and Assurance Detailed Decommissioning and Waste NNB-209-REP-000644 into stages. Where ONR so specifies, the Director Management Plan, which is applicable N/A licensee shall not commence nor thereafter to Hinkley Point C (NNB-PEA-REP-000002) proceed from one stage to the next of the decommissioning without the consent of ONR. The arrangements shall include a requirement for the provision of adequate Pre-Ops Director Procedures are established to: Manage Safety Reports documentation to justify the safety of the (a) divide, where proposed decommissioning and shall appropriate, the decommissioning NNB-202-PRO-000005 where appropriate provide for the into stages described by the Detailed submission of this documentation to ONR Decommissioning and Waste Management Plan; N/A

(b) classify proposed decommissioning to its nuclear safety Manage Interfaces with Regulators significance; (c) prepare a safety case for each NNB-209-PRO-000026 (SZC- 100207786) proposed decommissioning; (Manage Incoming Regulatory (d) ensure proposals are not

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Licence Condition 35 – Decommissioning

Arrangements for Compliance Person Responsible for Non-Active Active LC Licence Condition Comments Decommissioning Compliance Pre-FID Phase Construction Phase Commissioning Commissioning Operation Phase Phase Arrangements Phase Phase implemented until the clearances Correspondence and Notifications) appropriate to the safety classification have been obtained; (Manage Outgoing Regulatory Correspondence) (e) ensure, where specified by ONR, no such stage proceeds without the consent or agreement of ONR; Define, Manage and Release Key Hold Points (f) submit, where NNB-209-PRO-000025 appropriate, the safety

documentation to ONR

Arrangement: LC 22

Arrangement: LC 35

35(6) The licensee shall if so directed by ONR Engineering and None Arrangement: LC 22 where it appears to them to be in the Delivery Director interests of safety, commence Arrangement: LC 35 decommissioning in accordance with the N/A aforesaid arrangements and Manage Interfaces with Regulators decommissioning programmes NNB-209-PRO-000026 (SZC- 100207786) (Manage Incoming Regulatory Correspondence and Notifications)

35(7) The licensee shall, if so directed by ONR, Engineering and None Arrangement: LC 22 halt the decommissioning of a plant and Delivery Director N/A the licensee shall not recommence such Arrangement: LC 35 decommissioning without the consent of Manage Interfaces

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Licence Condition 35 – Decommissioning

Arrangements for Compliance Person Responsible for Non-Active Active LC Licence Condition Comments Decommissioning Compliance Pre-FID Phase Construction Phase Commissioning Commissioning Operation Phase Phase Arrangements Phase Phase ONR with Regulators NNB-209-PRO- 000026 (SZC- 100207786) (Manage Incoming Regulatory Correspondence and Notifications)

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Licence Condition 36 – Organisational Capability

Arrangements for Compliance

Person Responsible Non-Active Active LC Licence Condition for Compliance Comments Decommissioning Pre-FID Phase Construction Phase Commissioning Commissioning Operation Phase Arrangements Phase Phase Phase

36(1) The licensee shall provide and maintain HR Director The Company Manual provides an adequate financial and human resources overview of the route to funding Company Manual to ensure the safe operation of the licensed site. 100200192

The Company Manual describes the governance process to ensure the Company Manual safe operation of the site 100200192

The Nuclear Baseline describes NNB GenCo (SZC) Nuclear Baseline Statement human resources to ensure the safe operation of the licensed site. 100200200

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Licence Condition 36 – Organisational Capability

Arrangements for Compliance

36(2) Without prejudice to the requirements HR Director The Nuclear Baseline provides the of paragraph 1, the licensee shall make benchmark against which and implement adequate arrangements organisational changes can be to control any change to its assessed for impact on nuclear Shadow Working organisational structure or resources safety. which may affect safety. NNB GenCo (SZC) Nuclear Baseline Statement- 100200200 Sufficient organisational capability is maintained by controlling changes to Manage Organisational Change NNB-302-PRO-000015 the nuclear baseline. Maintain the Nuclear Baseline Statement and Data- NNB-302-PRO-000010 The management of organisational change process defines the controls applied to organisational change.

36(3) The licensee shall submit to ONR for HR Director None Control Regulatory Approved Management Arrangements approval such part or parts of the aforesaid arrangements as ONR may NNB-102-PRO-000064 (SZC- 100207813) specify.

36(4) The licensee shall ensure that once HR Director None approved no alteration or amendment is Control Regulatory Approved Management Arrangements made to the approved arrangements unless ONR has approved such alteration NNB-102-PRO-000064 (SZC- 100207813) or amendment.

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Licence Condition 36 – Organisational Capability

Arrangements for Compliance

36(5) The aforesaid arrangements shall HR Director Categorisation of organisational provide for the classification of changes changes and the documents required to the organisational structure or to justify them are defined in the resources according to their safety Management of Organisational significance. The arrangements shall Change procedure. Manage Organisational Change NNB-302-PRO-000015 include a requirement for the provision of adequate documentation to justify the Manage Interfaces with Regulators- NNB-209-PRO-000026 (SZC- 100207786) safety of any proposed change and shall where appropriate provide for the submission of such documentation to ONR.

36(6) The licensee shall if so directed by ONR HR Director NNB GenCo (SZC) shall, if so directed, halt the change to its organisational halt organisational changes to Manage Interfaces with Regulators- NNB-209-PRO-000026 (SZC- 100207786) structure or resources and the licensee structure or resources and shall not shall not recommence such change recommence without ONR consent Manage Organisational Change- NNB-302-PRO-000015 without the consent of ONR. Define, Manage and Release Key Hold Points- NNB-209-PRO-000025

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APPENDIX B- LICENCE INSTRUMENT RECIPIENTS

LC Clause Power Type NNB Recipient NNB Secondary Recipients NNB Response / Request  Safety, Licencing and Assurance Director Consent / Direction /  Managing Director Licence Condition Owner 1 3 Primary Company Secretary Approval  Licence Condition Owner responsible for original Licence (See Appendix A) Instrument 1 Primary Specification / Direction  Safety, Licencing and Assurance Director 2 Primary Specification / Approval  Managing Director Licence Condition Owner 2 Company Secretary 3 Primary Approval  Engineering and Delivery Director (See Appendix A) 5 Primary Specification / Direction 1 Derived Agreement/Acknowledgment  Safety, Licencing and Assurance Director 3 Primary Specification / Approval  Managing Director Licence Condition Owner 3 4 Primary Approval Company Secretary  Engineering and Delivery Director (See Appendix A) 5 Primary Specification / Consent 6 Primary Direction / Consent 3 Primary Specification / Approval  Safety, Licencing and Assurance Director  Managing Director Licence Condition Owner 4 4 Primary Approval Company Secretary  Pre-Operations Director (See Appendix A)  Engineering and Delivery Director 5 Primary Specification / Consent  Safety, Licencing and Assurance Director 1 Primary Consent  Managing Director  Engineering and Delivery Director Licence Condition Owner 5 Company Secretary  Pre-Operations Director (See Appendix A) 3 Primary Approval

2 Primary Approval  Safety, Licencing and Assurance Director Licence Condition Owner 6 Company Secretary 3 Primary Specification / Approval  Managing Director (See Appendix A)

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LC Clause Power Type NNB Recipient NNB Secondary Recipients NNB Response / Request 4 Primary Approval  Safety, Security and Assurance Director 5 Primary Specification  Finance Director 1 Primary Specification  Safety, Licencing and Assurance Director Licence Condition Owner 7 2 Primary Specification / Approval Company Secretary  Managing Director  Engineering and Delivery Director SZC (See Appendix A) 3 Primary Approval  Safety, Licencing and Assurance Director 2 Primary Specification / Approval  Managing Director Licence Condition Owner 10 Company Secretary  Pre-Operations Director (See Appendix A) 3 Primary Approval

2 Primary Specification / Approval  Safety, Licencing and Assurance Director  Managing Director Licence Condition Owner 11 Company Secretary 3 Primary Approval  Engineering and Delivery Director SZC (See Appendix A) 5 Primary Specification 3 Primary Specification / Approval  Safety, Licencing and Assurance Director  Managing Director Licence Condition Owner 12 4 Primary Approval Company Secretary  Pre-Operations Director (See Appendix A) 5 Primary Notification 1b Primary Specification  Safety, Licencing and Assurance Director  Managing Director 1c Primary Specification  Safety, Security and Assurance Director

2 Primary Approval 13 Licence Condition Owner Company Secretary 3 Primary Approval (See Appendix A)

5 Primary Notification / Agreement

9 Primary Specification

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LC Clause Power Type NNB Recipient NNB Secondary Recipients NNB Response / Request 11 Primary Approval

12 Primary Approval

2 Primary Specification / Approval  Safety, Licencing and Assurance Director  Managing Director Licence Condition Owner 14 3 Primary Approval Company Secretary  Engineering and Delivery Director (See Appendix A) 4 Primary Specification  2 Primary Specification / Approval Safety, Licencing and Assurance Director  Managing Director Licence Condition Owner 15 3 Primary Approval Company Secretary  Engineering and Delivery Director (See Appendix A) 4 Primary Direction / Specification  Safety, Licencing and Assurance Director  Managing Director  Engineering and Delivery Director Licence Condition Owner 16 4 Primary Specification Company Secretary (See Appendix A)

 3 Primary Specification / Approval Safety, Licencing and Assurance Director  Managing Director Licence Condition Owner 17 4 Primary Approval Company Secretary  Engineering and Delivery Director (See Appendix A) 5 Primary Specification

 Safety, Licencing and Assurance Director 1 Primary Specification  Managing Director Licence Condition Owner 18 Company Secretary 2 Primary Specification / Approval  Pre-Operations Director (See Appendix A)  3 Primary Approval Engineering and Delivery Director 19 1 Derived Specification / Agreement Company Secretary  Safety, Licencing and Assurance Director Licence Condition Owner

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LC Clause Power Type NNB Recipient NNB Secondary Recipients NNB Response / Request 2 Primary Specification / Approval  Managing Director (See Appendix A) 3 Primary Approval  Engineering and Delivery Director 4 Primary Specification / Consent 5 Primary Direction / Consent Specification / Agreement /  Safety, Licencing and Assurance Director 1 Derived Acknowledgement  Managing Director Licence Condition Owner 20 2 Primary Specification / Approval Company Secretary  Engineering and Delivery Director 3 Primary Approval  Engineering and Delivery Director (See Appendix A) 4 Primary Specification / Consent 2 Primary Specification / Approval  Safety, Licencing and Assurance Director 3 Primary Approval  Managing Director Licence Condition Owner 21 Company Secretary 4 Primary Specification / Consent  Engineering and Delivery Director (See Appendix A) 8 Primary Notification / Consent  Safety, Licencing and Assurance Director 2 Primary Specification / Approval  Managing Director  Engineering and Delivery Director 3 Primary Approval Licence Condition Owner 22 Company Secretary  Pre-Operations Director 4 Primary Specification / Consent (See Appendix A)

5 Primary Direction / Consent

2 Primary Specification  Safety, Licencing and Assurance Director  Managing Director 4 Primary Specification / Approval Licence Condition Owner 23 Company Secretary  Pre-Operations Director (See Appendix A) 5 Primary Approval  Engineering and Delivery Director 6 Primary Agreement / Approval 3 Primary Specification  Safety, Licencing and Assurance Director  Managing Director  Licence Condition Owner 24 5 Primary Specification / Approval Company Secretary Pre-Operations Director  Engineering and Delivery Director (See Appendix A) 6 Primary Approval

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LC Clause Power Type NNB Recipient NNB Secondary Recipients NNB Response / Request  Safety, Licencing and Assurance Director 3 Primary Specification Licence Condition Owner 25 Company Secretary  Managing Director (See Appendix A) 4 Primary Specification  Pre-Operations Director 2 Primary Specification / Approval  Safety, Licencing and Assurance Director 3 Primary Approval  Managing Director Licence Condition Owner 28 4 Primary Specification / Approval Company Secretary  Pre-Operations Director (See Appendix A) 5 Primary Approval  Engineering and Delivery Director 7 Primary Agreement  Safety, Licencing and Assurance Director  Managing Director Licence Condition Owner 29 1 Primary Specification Company Secretary  Pre-Operations Director (See Appendix A)  Engineering and Delivery Director  Safety, Licencing and Assurance Director 2 Primary Agreement  Managing Director Licence Condition Owner 30 Company Secretary  Pre-Operations Director (See Appendix A) 3 Primary Specification / Consent

 Safety, Licencing and Assurance Director 1 Primary Direction / Specification  Managing Director Licence Condition Owner 31 Company Secretary  Pre-Operations Director (See Appendix A) 2 Primary Consent

 Safety, Licencing and Assurance Director 2 Primary Specification / Approval  Managing Director  Engineering and Delivery Director 3 Primary Approval Licence Condition Owner 32 Company Secretary (See Appendix A) 4 Primary Specification

5 Primary Specification / Approval

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LC Clause Power Type NNB Recipient NNB Secondary Recipients NNB Response / Request  Safety, Licencing and Assurance Director  Managing Director  Engineering and Delivery Director SZC Licence Condition Owner 33 - Primary Direction / Specification Company Secretary (See Appendix A)

 Safety, Licencing and Assurance Director  Managing Director  Engineering and Delivery Director Licence Condition Owner 34 3 Primary Approval Company Secretary (See Appendix A)

3 Primary Specification / Approval  Safety, Licencing and Assurance Director  Managing Director 4 Primary Approval  Engineering and Delivery Director Licence Condition Owner 35 Company Secretary  Pre-Operations Director 5 Primary Specification / Consent (See Appendix A) 6 Primary Direction 7 Primary Direction / Consent Agreement /  Safety, Licencing and Assurance Director 2 Derived Acknowledgement  Managing Director  HR Director 3 Primary Specification / Approval Licence Condition Owner 36 Company Secretary  Engineering and Delivery Director (See Appendix A) 4 Primary Approval

6 Primary Direction / Consent

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APPENDIX C - ADOPTION PHASE. This breaks the application down further and splits construction into a phase before First Nuclear Safety Concrete (FNSC). The definitions are as follows,  Category 1- Full process is available. This would be control of property transactions- as the site will be owned from Licencing.  Category 2- Proportionate arrangements are in place. An example of this would be Restrictions of Nuclear matter on the site- where proportionate measures (meeting H&SAW and CDM) requirements will be put in place to control the use of sources on site for construction purposes.  Category 3- Arrangements not required at this point. An example of this would be “accumulation of radioactive waste that would not occur until active commissioning and waste is generated.

LC Condition Construction Construction Non-Active Active Operation Decommissioning (FNSC) Commissioning Commissioning 1 Interpretation N/A N/A N/A N/A N/A N/A 2 Marking of the Site Boundary 2 2 2 1 1 1 3 Control of Property Transactions 1 1 1 1 1 1 4 Restrictions on Nuclear Matter on the Site 2 2 2 1 1 1 5 Consignment of Nuclear Matter 2 2 2 1 1 1 6 Documents, Records, Authorities and Certificates 2 2 2 2 1 1 7 Incidents on the Site 2 1 1 1 1 1 8 Warning Notices 2 2 2 1 1 1 9 Instructions to Persons on the Site 2 2 2 1 1 1 10 Training 2 2 2 1 1 1 11 Emergency Arrangements 2 2 2 1 1 1 12 Duly Authorised and Other Suitably Qualified and 2 2 2 1 1 1 Experienced Persons 13 Nuclear Safety Committee 1 1 1 1 1 1

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LC Condition Construction Construction Non-Active Active Operation Decommissioning (FNSC) Commissioning Commissioning 14 Safety Documentation 2 2 2 1 1 1 15 Periodic Review 3 3 3 3 1 1 16 Site Plans, Designs and Specifications 2 2 2 1 1 1 17 Management Systems 2 2 2 1 1 1 18 Radiological Protection 2 2 2 1 1 1 19 Construction or Installation of New Plant 2 2 1 1 1 1 20 Modification to Design of Plant under Construction 1 1 1 1 N/A N/A 21 Commissioning 3 3 2 1 1 1 22 Modification or Experiment on Existing Plant 3 3 3 3 1 1 23 Operating Rules 3 3 3 1 1 1 24 Operating Instructions 3 3 2 1 1 1 25 Operational Records 3 3 3 2 1 1 26 Control and Supervision of Operations 3 3 2 2 1 1 27 Safety Mechanisms, Devices and Circuits 3 2 2 1 1 1 28 Examination, Inspection, Maintenance and Testing 3 2 2 1 1 1 29 Duty to Carry Out Tests, Inspections and Examinations 3 2 2 1 1 1 30 Periodic Shutdown 3 3 3 2 1 1 31 Shutdown of Specified Operations 3 3 3 1 1 1 32 Accumulation of Radioactive Waste 3 3 3 1 1 1 33 Disposal of Radioactive Waste 3 3 3 1 1 1 34 Leakage and Escape of Radioactive Material and 3 3 3 1 1 1 Radioactive Waste 35 Decommissioning 3 3 3 2 2 1 36 Organisational Capability 2 2 2 1 1 1

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NNB GENERATION COMPANY (SZC) LTD

COMPANY DOCUMENT

FORWARD WORK PLAN- SIZEWELL C

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NOT PROTECTIVELY MARKED 100200229 Version 003 TABLE OF CONTENTS

1 Introduction ...... 5 1.1 Purpose...... 5 1.2 Scope ...... 7 1.3 Organisational Development ...... 7 1.4 Safety Case ...... 7 1.5 Compliance Development ...... 7 1.6 Hold Points ...... 8 1.7 Licence Condition Compliance ...... 8 1.8 References and Definitions ...... 11 2 Forward Work Plan ...... 12 3 Pre-Construction- up to 2024 ...... 13 3.1 Organisational Development ...... 13 3.2 Safety Case ...... 14 3.3 Compliance Development ...... 15 3.4 Hold Points ...... 16 4 Construction ...... 17 4.1 Organisational Development ...... 17 4.2 Safety Case ...... 17 4.3 Compliance Development ...... 18 4.4 Hold Points ...... 18 5 Non-Active Commissioning ...... 18 5.1 Organisational Development ...... 19 5.2 Safety Case ...... 19 5.3 Compliance Development ...... 19 5.4 Hold Points ...... 20 6 Radioactive Commissioning ...... 20 6.1 Organisational Development ...... 21 6.2 Safety Case ...... 21

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NOT PROTECTIVELY MARKED 100200229 Version 003 6.3 Compliance Development ...... 21 6.4 Hold Points ...... 22 7 Operation ...... 22 7.1 Organisational Development ...... 22 7.2 Safety Case ...... 23 7.3 Compliance Development ...... 23 8 Decommissioning ...... 23 8.1 Safety Case ...... 23 9 Managing the Forward Work Plan ...... 23 9.1 Self-Regulation ...... 23 9.2 Approach ...... 24 9.3 Plan ...... 24 9.4 Compliance Assessment ...... 24 9.5 Procedure Change ...... 25 9.6 Forward Work Plan Review ...... 25 9.7 Project Plan ...... 25 9.8 Commitments ...... 25 10 Conclusion ...... 25

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NOT PROTECTIVELY MARKED 100200229 Version 003 1 Introduction NNB Generation Company (SZC) Limited (NNB GenCo (SZC)) has utilised Office for Nuclear Regulation (ONR) guidance in developing the Nuclear Site Licence (NSL) Application for Sizewell C (SZC). In particular, the Application is structured to address ONR guidance set forth in:  The Processing of Licence Applications for New Nuclear Sites [Ref. 1]; and  The Licensing of Nuclear Installations [Ref. 2]. This guidance acknowledges, however, that the organisation and management structure set out in the nuclear baseline and in the application is not static but will evolve consistent with the various project lifecycle phases. This Forward Work Plan (FWP) is an integral part of the NSL Application by NNB GenCo for SZC, and provides a description of the plans and activities being carried out by NNB GenCo (SZC) in order to achieve readiness for granting of the NSL and subsequent SZC project lifecycle phases. This includes plans for developing the organisation, associated management arrangements, and safety cases for the later phases. Sizewell C is intended to be a replica of Hinkley Point C, and a “Second of a Kind” (SOAK) plant, the design of the plant will have incorporated the UK context of the Generic Design Assessment and will have incorporated GDA assessment findings and will be equivalent of the Reference Configuration 2 (RC2) of Hinkley Point C. This means that the organisation will be smaller, with much less basic design and engineering required. The organisation will be concentrating on execution and will be developed using the learning and relevant good practices from HPC. As would be expected, the level of detail in the FWP at the point of applying for the NSL is greater towards the earlier phases of the Project. The plan of activities for later phases will be developed further as the Project progresses. In this way NNB GenCo (SZC) will comply with all aspects of the licence from the point of NSL granting and through all SZC project lifecycle phases.

1.1 Purpose The FWP describes plans and activities relevant to the NSL being undertaken by NNB GenCo (SZC) from the submission of the NSL Application through all the project lifecycle phases. The timing for each element of the FWP will be based on development and implementation of arrangements appropriate to the following phases of the project lifecycle in Figure 1:

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Phase Hold Point

Pre-Construction N/A

Construction First Nuclear Safety Related Concrete

Non-Active Commissioning First commissioning of systems

Radioactive Commissioning First Nuclear Fission. (withdrawal of shutdown banks with fuel in core)

Operation Handover to Operating Entity

(Rating Certificate)

Decommissioning Removal of last fuel from core and placement into fuel ponds following last operational cycle.

Figure 1- Project Phases These phases are not necessarily distinct and may overlap. For example, some design activities for some later construction activities may still be ongoing during early construction activities related to building foundations. Similarly, 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 EPR units at SZC will be staggered, such that the first unit is expected to become operational while the second unit is still undergoing construction and commissioning. Each of these phases of the project will necessitate changes to the organisation and different controls and programmes. Furthermore, even within a phase, the organisation and programmes may need to change depending upon the activities being conducted and to reflect lessons learned, particularly from the sister project at Hinkley Point C. NNB GenCo (SZC) fully appreciates that phases of the project will overlap, therefore there will be times when NNB GenCo (SZC) will be required to have established and be simultaneously implementing organisational and programmatic controls for more than one phase. As would be expected at this stage in the SZC lifecycle, the level of maturity of the programme of activities underpinning this FWP decreases further down the SZC lifecycle. The requirements for moving to subsequent phases will be reviewed as part of the activities for transiting phases.

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NOT PROTECTIVELY MARKED 100200229 Version 003 1.2 Scope This section lists the areas included in the FWP and provides a description of the activity. The organisation will develop as the project moves through the lifecycle phase. Throughout the project, certain documentation will also be subject to review and update to ensure that they sufficiently describe the requirements for the next phase in advance of project need. NNB GenCo (SZC) will review and update Company arrangements as appropriate in accordance with project processes to ensure fit for purpose arrangements are in place. The Integrated Management System (IMS) will be updated as necessary, providing a reference point for the process framework. The IMS programme will drive and govern the development and revision of all management arrangements, systems, tools, controls and governance against the needs of the programme and the business requirements, recognising the need for these to work effectively in multiple locations.

1.3 Organisational Development The NNB GenCo (SZC) organisation will continue to grow through the project lifecycle to ensure that the appropriate knowledge and competence exists in the licensee organisation at the appropriate time. Implementation of the strategies for developing Intelligent Customer status and developing an Independent Nuclear Assurance (INA) capability are two key elements NNB GenCo (SZC) will pursue in the early phases to ensure they become a capable organisation with a strong nuclear safety culture. These are embodied in the Resource Strategy [Ref 4] owned by NNB GenCo (SZC)’s Human Resources department. The Company Manual and Nuclear Baseline be living documents which will be updated to reflect the status of the organisation at each phase in the SZC lifecycle.

1.4 Safety Case The Generic Design Assessment (GDA) process provides a generic safety case for the UK EPR. The SZC reference design has been developed using the GDA reference design and HPC Reference Configuration 2 (RC2) as the basis and site-specific aspects such as geology, geography and the marine environment will be incorporated for SZC. Documentation will be developed to adequately assess the safety and environmental impacts of SZC as a site and confirm that the risks posed are acceptable, commensurate with the different stages in the SZC lifecycle.

1.5 Compliance Development NNB GenCo (SZC) is developing and implementing appropriate and proportionate arrangements for ensuring compliance with all 36 Licence Conditions identified in the ONR Licence Condition Handbook

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NOT PROTECTIVELY MARKED 100200229 Version 003 [Ref. 3]. NNB GenCo (SZC) staff and contractors will be trained in the requirements of these arrangements as required, and the arrangements may be updated because of lessons learnt during implementation. Additional details on Licence Condition compliance are provided in Section 1.3. As NNB GenCo (SZC) moves through the SZC lifecycle phases, appropriate security arrangements will be developed and implemented in preparation for the receipt of nuclear matter at site. Arrangements for Personnel and Information Security are already in place now. These arrangements will be amended as required in the future.

1.6 Hold Points NNB GenCo (SZC) has established a graded system of hold points in accordance with the hold point process [Ref. 10] to ensure ordered and sequential progress between defined steps in the programme and to ensure that these steps are managed in a safe, cost effective and controlled manner. Hold points cover activities beyond those associated with the NSL. The Hold Point List will change as the project progresses. NNB GenCo (SZC) will conduct a readiness review for each hold point to determine whether the hold point may be released. Each of the specific hold points will have a set of specified assessment criteria to determine whether permission should be granted by NNB GenCo (SZC) (and ONR/Environment Agency as appropriate) to release the hold point and proceed with the work. Only primary hold points aligned to transiting SZC project phases are identified in this FWP. Project controls are in place to ensure that the appropriate control measures are in place to ensure NNB GenCo (SZC)’s readiness to release any hold point is rigorously assessed prior to passing that point in the project.

1.7 Licence Condition Compliance Licence condition compliance is one of the scope areas of the FWP listed in Section 1.2. NNB GenCo’s Licence Condition compliance arrangements are referenced in the Compliance Matrix [Ref. 6] and progress has already been achieved in developing management arrangements to support compliance with the Licence Conditions. The following table describes the generic activities for developing and implementing arrangements for compliance with the Licence Conditions.

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Activities Detail Comment The procedures utilised by the SZC project are those developed initially by the HPC project and incorporate appropriate organisational learning. 1.1 Develop arrangement The Nuclear Site Licence Compliance Matrix: Sizewell C [Ref. 7] will indicate the requirement for 1. DEVELOPMENT commencing development of new procedures for continued licence condition compliance. Where required, systems and tools will be 1.2 Develop systems developed or revised to support processes.

Activities Detail Comment A standard format of training needs analysis is available for procedure owners to identify training needs and is facilitated via an inter project service agreement with HPC. 2.1 Training Needs Analysis This document allows training to be designed in terms of NNB GenCo (SZC) roles and levels of training required. Training requirements are reviewed and approved by TRAC (Training Review and Advisory Committee). The procedure owner develops the required training material with support from the Training 2.2 Prepare training Department. 2. TRAINING packages The Training Department also provides support for planning the training and inviting the delegates. A pilot of the training sessions may be carried out prior to full training delivery to ensure that the training is fit for purpose. The pilot will be carried 2.3 Training pilot out with delegates present and delivered by the trainers carrying out the subsequent training delivery. The appropriate levels of training will be planned and delivered in accordance with the Management 2.4 Training delivery of Training procedure, e.g. Awareness, Manager Briefing or Practitioner.

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Activities Detail Comment The procedure owner will carry out a pilot with 3.1 Pilot / Trial use of appropriate user representation (having received arrangement and training) to check that the procedure works and the systems relevant systems, tools and documents are in place for carrying out the procedure. In addition to ensuring the approved procedure is available in published area of the EDRMS, the 3. IMPLEMENTATION 3.2 Roll-out of procedure owner must ensure that appropriate arrangement communication is provided to NNB GenCo to advise that the procedure is ‘live’. NNB GenCo (SZC) managers must ensure that where 3.3 Implementation of required, the live procedures are used by their arrangement teams.

Activities Detail Comment

A schedule of process and team Self Assessments will be performed by the INA team. Process Owners will ensure that the self-assessments are 4.1 NNB GenCo (SZC) carried out in accordance with procedure and review of effectiveness within the timescale identified in the schedule. 4. SELF REGULATION of process The INA team will prepare a schedule of Independent Assessments. The INA team will perform the independent assessments in accordance with procedure. Organisational Learning be used to identify improvements to processes, procedures, systems 4.2 Organisational and competencies. Learning Process Key elements of this activity are Learning Reports, Corrective Action Programme and Continuous Improvement

Activities Detail Comment NNB GenCo (SZC) will assess its own readiness to receive the NSL or transit to a subsequent phase of 5. READINESS REVIEW 5.1 Readiness Review the project lifecycle. Key activities are controlled using hold points defined and controlled using the Hold Point Procedure.

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NOT PROTECTIVELY MARKED 100200229 Version 003 Section 2 identifies specific updates in each project phase regarding maintaining continuous Licence Condition compliance consistent with the needs of the project.

1.8 References and Definitions

Ref Title Location Document No. The Processing of Licence Applications for New ONR Website NS-PER-IN-003, Revision 4 Nuclear Sites. 1 http://www.onr.org.uk/operational/assessment/ ns-per-in-003.pdf Licensing Nuclear Installations. ONR Website 4th edition: January 2015. 2 http://www.onr.org.uk/licensing-nuclear- installations.pdf Nuclear Site Licence Conditions ONR Website February 2017 3 http://www.onr.org.uk/documents/licence- condition-handbook.pdf 4 Resource Strategy EDRMS 100196816 5 Company Manual EDRMS 100200192 6 Nuclear Baseline EDRMS 100200200 7 Nuclear Site Licence Compliance Matrix: SZC EDRMS 100200248 8 Management Systems Manual EDRMS 100200202 9 Management of Commitments EDRMS 100208058 10 Hold Point Process EDRMS 100200686

Definitions

Term / Abbreviation Definition

ALARP As Low as Reasonably Practicable CSP Construction Site Security Plan EDF Energy NGL EDF Energy Nuclear Generation Limited, EDFDCL EDF Development Company Limited EMIT Examination, Maintenance, Inspection and Testing EPR The Pressurised Water Reactor developed and trademarked by AREVA EDRMS Electronic Document and Records Management System FWP Forward Work Plan GDA Generic Design Assessment HPC Hinkley Point C HSE Health and Safety Executive INA Independent Nuclear Assurance

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Term / Abbreviation Definition

IMS Integrated Management System LC Licence Condition NNB GenCo NNB Generation Company Limited NSDAPs Nuclear Safety and Design Assessment Principles NSL Nuclear Site Licence NSLNSA Nuclear Site Licence Nuclear Safety Agreement ONR Office for Nuclear Regulation ONR CNSS Office for Nuclear Regulation, Civil Nuclear Security and Safeguards. PCSR Pre-Construction Safety Report POSR Pre-Operational Safety Report RD Responsible Designer RSR Radioactive Substances Regulations SoDA Statement of Design Acceptability SSP Site Security Plan SSR Station Safety Report SZA Decommissioned Magnox Power Plant, NDA SZB Sizewell B, PWR operated by EDF Energy Nuclear Generation ltd. SZC Sizewell C, twin EPR plant EDF Energy NNB GenCo (SZC) ltd

2 Forward Work Plan This section details the major FWP activities in each SZC project lifecycle phase for the scope areas described earlier. It is important to note that due to the financing arrangements for Sizewell C, it is unlikely that any procurement of long lead items or other safety related components will occur before the Final Investment Decision. The supply chain will be prepared and readied for an early start once the Final Investment Decision is achieved. This will also reflect in the size of the organisation and the maturity and implementation of processes and procedures. In order to estimate timescales before nuclear construction will occur, an indicative timescale is shown below in Fig.1 representing the relocated facilities and enabling works that must be undertaken prior to first nuclear safety related concrete on site- which is currently expected to be either galleries of the raft for unit 1. (Note that although the temporary sea wall is for the protection of construction activities, any interaction with the SZB safety case claims on sea protection from this area of site will be taken into account in the design and construction of the temporary sea defence.)

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Key: SDSR- Site Data Summary Report. JSSR- Justification of Site Suitability Report. FSRS-First Safety Related Structures. PCSR- Pre-Construction Safety Report. Fig 1.- Indicative early works programme.

3 Pre-Construction- up to 2024 NNB GenCo (SZC) is currently in the early Pre-Construction phase of the project, but no works will start on site, other than ground investigation and landscape, which includes relocated facilities and early works on site. During this phase, NNB GenCo (SZC) will be building capability within the organisation, preparing contracts and specifications based on organisational learning from HPC and preparation of the site for construction. This phase also includes a shadow working period for early processes and procedures for the project.

3.1 Organisational Development In this phase, the main areas of organisation development will be around continuing to recruit in all areas but particularly in the areas of the Design Authority, Safety Directorate and the Site Construction teams, developing the competency measurement and assessment tools for the organisation and formalising support from the HPC and EDF central support functions.

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NOT PROTECTIVELY MARKED 100200229 Version 003  Prior to NSL granting, NNB GenCo (SZC) will undertake the following activities around organisation development:  Appoint a Non-Executive Director to the Board prior to granting of the NSL with experience in nuclear safety,  Establish the Safety, Health and Environment Committee (SHEC),  Formally identify the SZC Chair of the Nuclear Safety Committee,  Recruit staff in accordance with the Resourcing Strategy,  Implement the arrangements for employment and secondment of staff,  Establish and demonstrate an effective Management of Change Committee,  Ensure the Nuclear Baseline across NNB GenCo (SZC),  Deliver Intelligent Customer role training,  Develop succession plans for posts with Nuclear Baseline roles,  Review the Nuclear Baseline role descriptors and post associations,  Review and update the resourcing plan in preparation for the Construction Phase,  Review the measurements in the Nuclear Baseline for the next phase, and  Implement tools to allow effective competency measurement and assessment. The agreement with EDF SA to act as Responsible Designer will be signed prior to NSL granting. The Company Manual [ref 5], Nuclear Baseline [ref 6] and ownership of the licence conditions via the compliance matrix [Ref. 7] will be kept under review will be updated around the time of NSL granting to reflect business developments e.g. funding via a Regulated Asset Base model and incorporate any lessons learnt from shadow working or regulator assessment and will be updated, as appropriate, prior to the Construction.

3.2 Safety Case

The SZC PCSR will be based upon Reference Configuration, Stage 2 (RC-2) of the HPC project, and will:

 Demonstrate the suitability of the SZC site, including validation of the bounding characteristics of the GDA site envelope and HPC design, and provide confidence that any parameters that are not bounded (or deviate from the GDA) can be suitably justified. As this is an ongoing process in the design phase, routine interaction with ONR will be performed to advise on progress, particularly the seismic spectra.

 Provide the basis to seek consent to construct once the site-specific aspects of the design are sufficiently detailed to support this.

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NOT PROTECTIVELY MARKED 100200229 Version 003  Illustrate the NNB GenCo (SZC) safety case production, review and acceptance processes. A schedule of technical documents associated with the PCSR will be prepared, discussed and submitted to ONR and interaction with ONR will be facilitated throughout the design assessment period. Seismic response and its interaction with the civil design is seen as a key to the replication of the design and therefore close interaction with ONR on this subject will be maintained through the design process. The SZC PCSR will be produced as part of the Hold Point List and consent for the first nuclear safety related concrete. Separate substantiation may also be provided to support additional activities which ONR may wish to permission. These will be identified through engagement with ONR and clearly captured on the Hold Point List. In addition, there will be interaction with other regulatory bodies such as the Environment Agency and the Maritime Management Organisation.

3.3 Compliance Development The transfer of land and transfer of licenced areas from SZB will be agreed and prepared prior to NSL granting. Any deemed consents requiring to be transferred to NNB GenCo (SZC from EDF Energy Nuclear Generation Ltd, that currently relate to SZB will be identified by EDF Energy Nuclear Generation Ltd and agreed with NNB GenCo (SZC) as part of this process. An indicative site layout showing the location and type of boundary markings, and the associated schedule of buildings, will be provided prior to NSL granting. Due to the extent of early works, and the scope and scale of the construction, the nuclear site boundary will not be marked prior to granting the NSL, and an alleviation from LC 2 will be sought from the ONR to delay the marking until practicable, the site will, however, have appropriate and proportionate access control and suitable security for a major construction site. Prior to NSL granting, NNB GenCo (SZC) will have a suite of company policies aligned with EDF Energy policies. In addition, NNB GenCo (SZC) will have:  Developed tools and systems to assist in the implementation of these arrangements.  Completed delivery of training associated with applicable LCs.  Moved into shadow working of these arrangements.  Assessed the adequacy of the arrangements during shadow working, and used any lessons learnt to improve the arrangements, and  Made sure the appropriate resources are in place to make the arrangements work. Details of compliance arrangements can be found in the Compliance Matrix, [Ref. 7]. During the Pre-Construction phase, arrangements supporting LCs will be updated as required in preparation for entering the Construction phase, recognising the change in hazard from activities being

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NOT PROTECTIVELY MARKED 100200229 Version 003 undertaken at SZC site during the Construction phase. Key arrangements to be developed and/or updated include:  The process for the periodic assessment of culture, including the use of performance indicators that are both reactive and proactive allowing effective management influence,  Arrangements for compliance and oversight, conflict resolution, and Independent Technical Assessment,  Arrangements for dealing with incidents at site,  Emergency plans, considering conventional hazards introduced during construction as well as the adjacent nuclear facilities,  Arrangements for preservation/maintenance of equipment at site to maintain their safety qualification prior to commissioning systems and plant,  Arrangements for ensuring that NNB GenCo (SZC)’s arrangements for dealing with emergencies associated with conventional hazards on the SZC site align with arrangements for being adjacent to an existing nuclear facility; and  Arrangements for ensuring that competent persons are appointed to control and supervise commissioning activities. NNB GenCo (SZC) will ensure the Decommissioning and Waste Management Plan which underpins the FDP is reviewed and updated as required. NNB GenCo (SZC) will ensure appropriate third-party liability cover is in place prior to NSL granting. The MSM [Ref. 8], Compliance Matrix [Ref. 7] and Forward Work Plan will be updated as required. At the Pre-Construction Phase, NNB GenCo (SZC) is also developing and implementing the Construction Site Security Plan (CSP). The CSP will outline key threats, security objectives as mitigations to those threats and the personnel, information and physical security measures required to achieve those objectives.

3.4 Hold Points NNB GenCo (SZC) has identified a primary hold point that corresponds to the transition from the Pre- Construction Phase to the Construction phase. This hold point, First Nuclear Safety Concrete, provides the release to pour the first safety related concrete, and is likely to be the construction of the Unit 1 stressing gallery, approximately 4.5 years post-FID, although work on the temporary sea defence will be considered against the needs of the SZB safety case. It should be noted that the civil construction plan is under constant review during this early phase and is learning from HPC, this means these dates may change. During the Pre-Construction phase, NNB GenCo (SZC) will internally agree upon the acceptance criteria for release of this hold point, undertake the activities to meet the acceptance criteria, and release the hold point prior to moving to the Construction phase.

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NOT PROTECTIVELY MARKED 100200229 Version 003 4 Construction The Construction Phase covers the construction and installation of plant and equipment at SZC site. This phase will not commence until issuance of requisite permits, permissions, and authorisations, including the NSL. NNB GenCo (SZC) 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 for Unit C2.

4.1 Organisational Development In this phase, the main areas of organisation development will be around developing the organisation capabilities for the ongoing Construction phase and in readiness for moving to the Non-Active Commissioning phase. This will involve continuing to recruit into the Site Construction Teams and looking towards the Pre-Operations Directorate. NNB GenCo (SZC) will undertake the following activities around organisation development:  Recruit staff in accordance with the Resourcing Strategy, in particular in the areas of the Site Construction and Pre-Operation organisations.  Continue to deliver Intelligent Customer role training.  Continue to develop succession plans for posts with Nuclear Baseline roles.  Review and update the resourcing plan in preparation for the Non-Active Commissioning Phase.  Assess the organisation capability ahead of starting Sizewell C work.  Assess competencies for moving into commissioning; and  Continue to review and improve the company culture using Key Performance Indicators (KPIs), and periodic reassessment. The Company Manual and Nuclear Baseline will be updated prior to moving into the Non-Active Commissioning phase to reflect these developments and incorporate any lessons learnt from the Construction phase. Ownership of the Licence Conditions will be kept under review as the organisation structure develops.

4.2 Safety Case Recognising the duration of the Construction phase, the PCSR and supporting technical documentation will be updated as required during this phase. Design changes during construction will be categorised and cleared in accordance with NNB GenCo (SZC) arrangements. During the Construction phase, NNB GenCo (SZC) will develop the commissioning schedules and success criteria clearly identified.

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NOT PROTECTIVELY MARKED 100200229 Version 003 4.3 Compliance Development In preparation for moving to the Non-Active Commissioning phase, the arrangements demonstrating compliance with the LCs will be reviewed to make sure they adequately support the transition into commissioning. In particular, the following activities will be undertaken:  Develop and implement the Commissioning Manual and programme, identifying the logic, safe systems of work and documentation to safely undertake commissioning. This will also ensure there is an effective system in place for tracking all commissioning work activities, establishing linkages between them, link to the existing processes for raising queries, concessions and modification during commissioning, and ensure arrangements are in place for any commissioning happening off the nuclear licensed site.  Identify competent persons for the Non-Active Commissioning phase.  Identify processes for undertaking examination, inspection, maintenance and testing of equipment installed at site, and points of handover from installation contractors to NNB GenCo (SZC).  Update the INA strategy and plan three years prior to entering the Commissioning phase, to review the development of and recognise the transfer of responsibility for ITA from Design Authority to Safety Directorate.  Update the CSP ready for commissioning; and  Review and update the Decommissioning and Waste Management Plan which underpins the FDP, if required. The MSM [Ref. 8], Compliance Matrix [Ref. 7] and Forward Work Plan will be updated as required.

4.4 Hold Points NNB GenCo (SZC) has identified a primary hold point that corresponds to the transition from the Construction phase to the Non-Active Commissioning phase. This hold point, Non-Active Commissioning, provides the release of commissioning of the first safety related system. During the Construction phase, NNB GenCo (SZC) will internally agree the acceptance criteria for release of this hold point and the subsequent primary hold points in the SZC lifecycle, undertake the activities to meet the acceptance criteria for release of the Non-Active Commissioning hold point, and release the hold point prior to moving to the Non-Active Commissioning.

5 Non-Active Commissioning The Non-Active Commissioning phase includes inactive commissioning of safety related systems and components and hot functional testing. Fuel delivery will not take place until the appropriate non-active commissioning is complete for the structures and systems associated with fuel storage and the appropriate systems for handling radioactive material and waste.

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NOT PROTECTIVELY MARKED 100200229 Version 003 The focus of developments in this phase will be for receipt of nuclear matter on site.

5.1 Organisational Development In this phase, the main areas of organisation development will be around continuing to develop the capabilities for the ongoing Non-Active Commissioning phase and developing the organisation capabilities in readiness for receiving nuclear matter onto site and moving to the Radioactive Commissioning phase, continuing to recruit into the Pre-Operations Directorate. NNB GenCo (SZC) will undertake the following activities around organisation development:  Recruit staff in accordance with the Resourcing Strategy, in the areas of the Pre-Operation and Security organisations.  Continue to deliver Intelligent Customer role training.  Continue to develop succession plans for posts with Nuclear Baseline roles.  Review and update the resourcing plan in preparation for the Radioactive Commissioning Phase.  Assess competencies for moving into Radioactive Commissioning; and  Continue to review and improve the company culture using Key Performance Indicators (KPIs), and periodic reassessment. The Company Manual and Nuclear Baseline will be updated as necessary prior to moving into the Radioactive Commissioning phase to reflect these developments and incorporate any lessons learnt from the Non-Active Commissioning phase. Ownership of the Licence Conditions will be kept under review as the organisation structure develops.

5.2 Safety Case The Non-Active Commissioning Reports will be prepared to substantiate the adequacy of Non-Active Commissioning and become part of the Pre-Operational Safety Report.

5.3 Compliance Development In preparation for moving to the Radioactive Commissioning Phase, the arrangements demonstrating compliance with the LCs will be reviewed to make sure they adequately support the transition into Radioactive Commissioning. In particular, the following activities will be undertaken:  Identify Duly Authorised Persons for the Radioactive Commissioning phase.  Provide the ONR CNSS with information on nuclear safeguards measures to verify that nuclear matter is properly accounted for.

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NOT PROTECTIVELY MARKED 100200229 Version 003  Shadow work the arrangements for receipt, handling and storage of nuclear matter and radioactive waste on site.  Shadow work the arrangements for transportation of nuclear matter and radioactive waste on site and consignment from site.  12 months prior to fuel to site for the first unit the Site Emergency Plan will be produced, setting out the overall arrangements to be implemented in response to on-site accidents or emergencies, including those that have off-site implications requiring emergency response extending to a wide area beyond the site in support of REPPIR requirements.  6 months prior to fuel to site for the first unit detailed instructions in the Site Emergency Handbook and other underlying documentation for implementing the arrangements will be established.  Seek Regulatory approval of those emergency arrangements prior to receipt of nuclear fuel on site.  Authorise the Technical Specifications for use during Radioactive Commissioning.  The Site Security Plan will be prepared for implementation.  Validate EMIT schedules for use during Radioactive Commissioning.  Review and update the Decommissioning and Waste Management Plan which underpins the FDP, if required.  The MSM, Compliance Matrix and Forward Work Plan will be updated as required.

5.4 Hold Points NNB GenCo (SZC) has identified the primary hold point Active Commissioning that corresponds to the transition from the Non-Active Commissioning phase to the Radioactive Commissioning phase. During the Non-Active Commissioning phase, NNB GenCo (SZC) will internally undertake the activities to meet the acceptance criteria for release of this hold point, and release the hold point prior to moving to the Radioactive Commissioning Phase.

6 Radioactive Commissioning The Radioactive Commissioning phase begins with nuclear fuel delivery and consists of active commissioning, such as testing of fuel storage systems following nuclear fuel receipt; loading of fuel in the reactor vessel, initial criticality, and power ascension testing.

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NOT PROTECTIVELY MARKED 100200229 Version 003 6.1 Organisational Development In this phase, the main areas of organisation development will be around continuing to develop the capabilities for the Radioactive Commissioning phase and developing the organisation capabilities in readiness for receiving the Rating Certificate and receiving Consent to Operate. NNB GenCo (SZC) will undertake the following activities around organisation development:  Recruit staff in accordance with the Resourcing Strategy, in particular in the areas of the Pre- Operation and Security organisations.  Continue to deliver Intelligent Customer role training.  Continue to develop succession plans for posts with Nuclear Baseline roles.  Review and update the resourcing plan in preparation for the Operation Phase;  Assess competencies for moving into Operation; and  Continue to review and improve the company culture using Key Performance Indicators (KPIs), and periodic reassessment. The Company Manual and Nuclear Baseline will be updated prior to moving into the Operations phase to reflect these developments and incorporate any lessons learnt from the Radioactive Commissioning. Ownership of the Licence Conditions will be kept under review as the organisation structure develops.

6.2 Safety Case During the commissioning phases, NNB GenCo (SZC) will prepare the Active Commissioning Reports and develop the Pre-Operational Safety Report (POSR). The POSR will pull together all evidence to support operation including:  Design substantiation.  Safety Analysis; and  Testing/commissioning.

6.3 Compliance Development In preparation for moving to the Operation phase, the arrangements demonstrating compliance with the LCs will be reviewed to make sure they adequately support the transition into operations. In particular, the following activities will be undertaken:  Identify Duly Authorised Persons for the Operation phase.  Shadow work the arrangements for receipt, handling and storage of nuclear matter and radioactive waste on site.

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NOT PROTECTIVELY MARKED 100200229 Version 003  Finalise the arrangements for modifying existing plant, incorporating lessons learnt from using the LC20 arrangements through construction and commissioning.  Review and update the Decommissioning and Waste Management Plan which underpins the FDP, if required; and  Develop and implement the arrangements for undertaking periodic reviews of safety. The MSM [Ref. 8], Compliance Matrix [Ref. 7] and Forward Work Plan will be updated as required.

6.4 Hold Points NNB GenCo (SZC) has identified a primary hold point that corresponds to the transition from the Radioactive Commissioning phase to the Operation phase. This hold point, Rating Certificate, provides the application for permission to commence operations. During the Radioactive Commissioning phase, NNB GenCo (SZC) will internally undertake the activities to meet the acceptance criteria for release of this hold point, and release the hold point prior to moving to the Operation phase.

7 Operation The Operation Phase follows the completion of Radioactive Commissioning and NNB GenCo (SZC)’s lifting of its Hold Point for Rating Certificate. It includes maintenance, examination, testing, operation of the plant, and the treatment, processing, keeping, storing, accumulation or carriage of any radioactive waste. At this point in the SZC lifecycle, NNB GenCo will have developed an organisation capable of operating and maintaining the facilities at SZC, and has the tools, systems and processes to respond to the need to change its arrangements to reflect operational learning.

7.1 Organisational Development Due to the length of the Operation phase of the project, business as usual reviews and updates will be carried out to ensure the organisation structure and competencies remain fit for purpose. In this phase, the main areas of organisation development will be around succession planning and preparing for Decommissioning. NNB GenCo (SZC) will undertake the following activities around organisation development:  Recruit staff in accordance with the Resourcing Strategy.  Continue to develop succession plans for posts with Nuclear Baseline roles; and  Review and update the resourcing plan in preparation for the Decommissioning Phase. The Company Manual and Nuclear Baseline will be updated prior to moving into the Decommissioning phase to reflect these developments and incorporate any lessons learnt from the Operations. Ownership of the Licence Conditions will be kept under review as the organisation structure develops.

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NOT PROTECTIVELY MARKED 100200229 Version 003 7.2 Safety Case After a period to be agreed with ONR, and once operation at power is established, the POSR will become the Station Safety Report (SSR). Changes to the safety case will be captured under the arrangements for modifying existing plant, and periodic safety reviews will review the safety case in accordance with LC15. The safety case for decommissioning the facilities will be prepared to substantiate the methodology for decommissioning the plant prior to project need.

7.3 Compliance Development Periodic review and self-assessment may identify opportunities to learn from experience and improve arrangements during the period the plant is operating at SZC. This would be ‘normal business’. As the date for decommissioning approaches and the methodology for undertaking decommissioning at SZC is finalised, more detailed arrangements for dealing with decommissioning would be prepared. The MSM [Ref. 8], Compliance Matrix [Ref. 7] will be updated as required.

8 Decommissioning The Decommissioning phase consists of de-fuelling, dismantling, decommissioning, and removal of the plant following completion of operation. As part of granting the NSL, appropriate arrangement will have been put in place to ensure adequate funding provisions are in place and secured. This area of the FWP will be developed more fully during operations.

8.1 Safety Case A Decommissioning Safety Case will be prepared recognising any needs to phase the decommissioning of the facilities at SZC, and the best available techniques for decommissioning at the point of project need.

9 Managing the Forward Work Plan

9.1 Self-Regulation NNB GenCo (SZC) needs to assure itself that it has adequately prepared and implemented its arrangements, and that these are effective. Outputs need to be assessed and evidence provided that such outputs exist and that persons responsible for them understand their role and what is required. It is proposed to make use of the Assurance processes and procedures used on the HPC project, in particular those relating to Independent Nuclear Assurance, (INA).

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NOT PROTECTIVELY MARKED 100200229 Version 003 9.2 Approach Self-assessment and self-regulation enable NNB GenCo (SZC) to test and measure compliance with its own arrangements. This will enable confidence to be gained with the arrangements and, where necessary, improvements identified and implemented. NNB GenCo (SZC)’s strategy is three pronged: i. Compliance assessment ii. Self-assessment iii. Independent assessment During each assessment NNB GenCo (SZC) expects to identify improvements and define corrective actions. The implementation of these actions illustrates NNB GenCo’s commitment to self-regulation and continuous improvement.

9.3 Plan

9.4 Compliance Assessment This activity has been performed as part of the NSL Application readiness review and has been supported by independent and external resource. There is a process in place to capture learning points from the assessment and ensure that any identified corrective actions are completed. Self-Assessment Self-assessment is carried out by the process owner. Self-assessment is generally suitable from approximately two months after commencing use of the procedure. These activities will be captured in a programme used to manage resources. Findings from the Self-Assessment reviews will be captured in the Learning Report system and may generate corrective actions. Independent Assessment This is an activity performed using audit and internal inspection processes and tools. It is applied once procedures have been implemented for some time and may start around six months after commencing use of the procedure. The audit and internal inspection plan will be defined and managed by the safety directorate. Note: Both Self-Assessments and Independent Assessments generally target a process rather than a particular LC. So, one independent assessment may cover only part of a LC (e.g. procurement vs. LC19) or on the other hand parts of several LCs (e.g. LC 23/24).

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NOT PROTECTIVELY MARKED 100200229 Version 003 9.5 Procedure Change Changes identified during Self-Assessment and Independent Assessment will be managed via the agreed processes and procedures within the project.

9.6 Forward Work Plan Review The FWP will be reviewed as required throughout the project lifecycle.

9.7 Project Plan NNB GenCo (SZC) will prepare a project plan to manage the delivery of the FWP. (The Integrated Work Schedule). The project plan will be baselined for progress reporting and deliverable reports prepared monthly. NNB GenCo (SZC) Project Controls processes will be applied to ensure appropriate project management is in place to monitor and control delivery of the FWP.

9.8 Commitments NNB GenCo (SZC) has identified areas in the dossier where it has promised to deliver work in subsequent phases. These activities have been captured in the programme which underpins this FWP. Where appropriate, these promises will be captured in the NNB GenCo (SZC) Management of Commitments [Ref 9] to allow monitoring of closeout to be undertaken at a senior level within NNB GenCo (SZC).

10 Conclusion NNB GenCo (SZC) has implemented processes for organisational learning and is committed to continuous improvement of itself and its arrangements. NNB GenCo (SZC) have developed a Forward Work Plan which clearly identifies the activities NNB GenCo (SZC) are planning to undertake to ensure that their organisation and arrangements remain fit for purpose for all phase of the SZC lifecycle.

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648000.000E Copyright © 2020 NNB Generation Company (SZC) Limited. All rights reserved. No part of this drawing to be reproduced without prior permission. NOTES: NA NOT PROTECTIVELY MARKED PROPERTY OWNERSHIP INTELLECTUAL DOCUMENT SUB -TYPE DOCUMENT REFERENCE No. PAGE 1: Document related to Unit 1 DRAWING GRID / COORDINATE SYSTEM: Reproduced from Ordnance Survey map with the permission of UK PROTECTIVE MARKING: UK PROTECTIVE MARKING: SITE PLAN CONTRACTOR WBS CODE : CONTRACT NUMBER : CONTRACTOR REF. No. CONTRACTOR COMPANY TRADE NAME : CONTRACT PROJECT PLAN DOC. REF. No: Survey on behalf of the controller Her Majesty's Stationery Office © Crown SUBCONTRACTOR COMPANY TRADE NAME 1/1 SIZE 1:5000@A3 SCALE 0: Documents that relate exclusively to 9: Document that applies to buildings/systems OTHER GRID SITE LOCAL GRID copyright (2019). All Rights reserved. NNB GenCo Licence: 0100060408 NOT PROTECTIVELY MARKED 2: Document related to Unit 2 APPLICABILITY: REV. whole site ( e.g. parking, ancillary buildings...) buildings or systems that are common to the common to Unit 1 & 2 01 NNB GenCo (SZC) LTD. Project SZC X 14.05.20 X DATE A3 - X PREPARED X Contract No. / Orig. Co SB BY SZ0100 DESCRIPTION CHECKED 10m WIDE STERILE ZONE MEAN HIGH WATER MARK LINE SIZEWELL B EXISTING STRUCTURES SZC PERMANENT SECURITY FENCE & SZC NUCLEAR SITE LICENCE BOUNDARY DY BY NA NA : NNB: STATUS OWNERSHIP 0 NA S2 1 ISSUED FOR INFORMATION - For A0 and A1 : ABERPFTHLIJOOCGQUVWMNSZXKY / Zone Asset XX 2 zsaeocmuvnwxirfkhbdpqgyjlt 71423855690 This pattern must be entirely readable LICENCE AREA NUCLEAR SITE NUCL/REP/EPR/UKX NA SZC ( doc: SZ ) 3 - X SIZEWELL C 0 1st partner / Building NNB System NATIONAL GRID OSGB36 (To be defined in the contract project plan) 000 4 1 SUBCONTRACTOR DOCUMENT REF. No EDF CLASSIFICATION CODE NA NA NA EDF: REASONS FOR REVISION QRA RELATED 5 2 - 6 Doc. type DRW 9 7 8 - NA CONTRACTOR: 9 2nd partner 000 BUILDING SYSTEM NA 100104 Chrono No. Yes EDF 10 X APPROVED No BY - X