Executive summary
Date(s) of inspection: June 2024
Aim of inspection
The aim of the intervention is to sample NNB GenCo’s arrangements for compliance against Licence Condition (LC) 21 – Commissioning.
In October 2023, ONR undertook a readiness inspection on the commissioning arrangements ahead of the start of early commissioning which was due in November 2023. The inspection focused on the site health and safety arrangements, configuration control, handover arrangements, surveillance of Design, Manufacture Installation, Commission (DMIC) contractors and graded approach. The inspection was rated Amber and shortfalls were highlighted in all the above areas.
The proposed commissioning activities did not take place in November 2023 and currently the NNB led commissioning activities will start in July 2024. With the exception of the polar crane, the commissioning activities proposed for 2024 are enabling commissioning activities to allow the energisation of the Auxiliary Transformer (TAE). This inspection took place a few weeks before the planned start of the enabling commissioning activities, therefore, the LC21 arrangements related to those activities were expected to be sufficiently matured to provide ONR with the opportunity to test the arrangements and deep dive in some areas.
The objective of this inspection was to sample and test the LC 21 arrangements ahead of the enabling commissioning activities, focusing on how the gaps highlighted by the previous ONR inspection (IIS-51662) have been closed and the governance arrangements..
In October 2023, ONR undertook a readiness inspection on the commissioning arrangements ahead of the start of early commissioning which was due in November 2023. The inspection focused on the site health and safety arrangements, configuration control, handover arrangements, surveillance of Design, Manufacture Installation, Commission (DMIC) contractors and graded approach. The inspection was rated Amber and shortfalls were highlighted in all the above areas.
The proposed commissioning activities did not take place in November 2023 and currently the NNB led commissioning activities will start in July 2024. With the exception of the polar crane, the commissioning activities proposed for 2024 are enabling commissioning activities to allow the energisation of the Auxiliary Transformer (TAE). This inspection took place a few weeks before the planned start of the enabling commissioning activities, therefore, the LC21 arrangements related to those activities were expected to be sufficiently matured to provide ONR with the opportunity to test the arrangements and deep dive in some areas.
The objective of this inspection was to sample and test the LC 21 arrangements ahead of the enabling commissioning activities, focusing on how the gaps highlighted by the previous ONR inspection (IIS-51662) have been closed and the governance arrangements..
Subject(s) of inspection
- LC21 - Commissioning - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
In October 2023, ONR undertook a readiness inspection on the commissioning arrangements ahead of the start of early commissioning. The inspection focused on the site health and safety arrangements, configuration control, handover arrangements, surveillance of Design, Manufacture Installation, Commission (DMIC) contractors and graded approach. The inspection was rated Amber and shortfalls were highlighted in all the above areas.
From the evidence presented, ONR concluded, that the licensee had made good progress addressing the previously highlighted shortfalls and provided robust evidence of their governance arrangements. Furthermore, based on the sampled evidence, ONR judged that the LC21 arrangements are sufficiently developed for the start of the LVL boards commissioning. Therefore, the inspection was rated GREEN.
The inspection team acknowledge that significant work has been undertaking on addressing the gaps from previous inspection and noted areas of good practice.
The inspection team highlighted the challenges associated with the scalability of the arrangements, and this will be followed through planned inspections. The inspection team also noted that the arrangements were not stable in certain areas, and those are recorded as findings and will be followed through the existing regulatory issue, RI-11760.
From the evidence presented, ONR concluded, that the licensee had made good progress addressing the previously highlighted shortfalls and provided robust evidence of their governance arrangements. Furthermore, based on the sampled evidence, ONR judged that the LC21 arrangements are sufficiently developed for the start of the LVL boards commissioning. Therefore, the inspection was rated GREEN.
The inspection team acknowledge that significant work has been undertaking on addressing the gaps from previous inspection and noted areas of good practice.
The inspection team highlighted the challenges associated with the scalability of the arrangements, and this will be followed through planned inspections. The inspection team also noted that the arrangements were not stable in certain areas, and those are recorded as findings and will be followed through the existing regulatory issue, RI-11760.
Conclusion
From the evidence presented, ONR concluded, that the licensee had made good progress addressing the shortfalls highlighted by the previous ONR inspection (IIS-51662) and provided robust evidence of their governance arrangements. Furthermore, based on the sampled evidence, ONR judged that the LC21 arrangements are sufficiently developed for the start of the LVL boards commissioning. Therefore, the inspection was rated GREEN.
The inspection team acknowledge that significant work has been undertaking on addressing the gaps from previous inspection and noted areas of good practice, such as the lessons learnt from the commissioning of the polar crane or the LVL readiness exercise carried out by the commissioning team.
The inspection team highlighted the challenges associated with the scalability of the arrangements, and this will be followed through future planned inspections. The inspection team also noted that the arrangements were not stable in certain areas, and those are recorded below as findings.
The inspection team made a number of findings which will be monitored through the existing L3 regulatory issue (RI-11760). The findings were:
The inspection team acknowledge that significant work has been undertaking on addressing the gaps from previous inspection and noted areas of good practice, such as the lessons learnt from the commissioning of the polar crane or the LVL readiness exercise carried out by the commissioning team.
The inspection team highlighted the challenges associated with the scalability of the arrangements, and this will be followed through future planned inspections. The inspection team also noted that the arrangements were not stable in certain areas, and those are recorded below as findings.
The inspection team made a number of findings which will be monitored through the existing L3 regulatory issue (RI-11760). The findings were:
- Conventional health and safety. Licensee to consider incorporating the HPC/NNB site interface document within the CPED.
- Grading. Shortfalls were identified on the graded approach regarding stability of arrangements, clarity on assigning test grades to WOCs and verification of work on site.
- Configuration control – Clarity on who will undertake the role of PD is not clear in the documentation sampled. Guidance on complex and simple TMDs should also be included for the C&I TMDs.
- Handover arrangements. The TFC mentions commissioning control points A, B and C raised during the walkdowns ahead of TFC. Alignment is needed with the configuration control guidance. This finding also relates to the stability of arrangements.
- Handover arrangements. Clarity on statutory maintenance on DMIC contracts and how the licensee ensures compliance.