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Hinkley Point C - Inspection ID: 52694

Executive summary

Date(s) of inspection: July 2024

Aim of inspection

The aim of ONR’s inspection of the Hinkley Point C Unit 1 polar crane commissioning activities is to:

  • Establish whether NNB Generation Company (HPC) Limited's (hereafter referred to as NNB GenCo) arrangements for commissioning and surveillance of design, manufacture, install and commission (DMIC) contractors are suitable and sufficient;
  • Confirm that the arrangements are adequately implemented for commissioning activities associated with the polar crane; and,
  • Confirm that commissioning activities for the polar crane are being undertaken in a safe and controlled manner.

Subject(s) of inspection

  • LC17 - Management systems - Rating: Not rated
  • LC21 - Commissioning - Rating: Green
  • LC28 - Examination, inspection, maintenance and testing - Rating: Green
  • Lifting / LOLER - Rating: Not Rated
  • Provision and Use of Work Equipment Regulations 1998 (PUWER) - Rating: Green
  • Working at Height - Rating: Green

Key findings, inspector's opinions and reasons for judgement made

The inspection (HPC 24-52) provided sufficient regulatory confidence that NNB GenCo's implementation of arrangements for commissioning the Hinkley Point C Unit 1 polar crane for construction use are suitably robust, aligning with relevant good practice. NNB GenCo was able to demonstrate that its surveillance of the DMIC contractor was suitably robust. This was particularly evident during my observation of the commissioning activities.

The inspection concluded that NNB GenCo's activities at Hinkley Point C met relevant good practice in relation to Work at Height Regulations 2005, Provision and Use of Work Equipment Regulations 1998, Nuclear Site Licence Condition 21 (Commissioning) and Licence Condition 28 (Examination, inspection, maintenance and testing).

I provided advice to NNB GenCo where I judged it could make improvements to its arrangements or implementation. These were:

  1. Work at Height: gaps identified in netting providing protection from falling objects were observed. These should be repaired by the relevant person responsible for safety within the reactor building.
  2. Work at Height: emergency evacuation procedures should be practiced with new personnel from APCO (the manufacturer and organisation commissioning the polar crane) as soon as practicable.
  3. Licence Condition 17 (Management systems): a robust, formal process is required for the management of temporary means and devices and further scrutiny is required in ensuring all temporary means and devices are removed from the workface once commissioning plans are completed.

I judge these areas to be minor in respect to the scope of my inspection concerning the polar crane commissioning arrangements. NNB GenCo took actions to address items 1 and 2 during the inspection, and item 3 is currently being addressed via a new process. Therefore, I consider that they do not warrant tracking through a regulatory issue.

I also observed that NNB GenCo had not yet implemented arrangements in respect to organisation of lifting operations and thorough examination of the polar crane. Both must be in place before lifting operations commence for construction use.

I plan to hold a Level 4 (technical) meeting with NNB GenCo at the end of August 2024 ahead of its use. This meeting shall provide suitable evidence that appropriate arrangements are in place to comply with the Lifting Operations and Lifting Equipment Regulations 1998.

Conclusion

I was able to gain an appropriate insight into NNB GenCo's application of arrangements in relation to commissioning of the Unit 1 polar crane for construction activities. Overall I judge the following areas to be rated Green:

  • Compliance with the Provision and Use of Work Equipment Regulation 1998 and associated Approved Code of Practice and guidance L22
  • Work at Heigh Regulations 2005 and guidance to industry INDG401
  • Licence Condition 21 - Commissioning
  • Licence Condition 28 - Examination, inspection, maintenance and testing

This is because relevant good practice was generally met, with only minor shortfalls identified when compared with appropriate benchmarks.

There were two important areas related to lifting that I was not able to rate. This was due to either only a very limited scope within my inspection, or NNB GenCo's arrangements were not sufficiently mature. These were:

  • Licence Condition 17 - Management systems
  • Compliance with Regulations 8 and 9 of the Lifting Operations and Lifting Equipment Regulations 1998 (LOLER) and associated Approved Code of Practice and guidance L113

I advised NNB GenCo that I will follow these matters up through a Level 4 (technical) meeting. This will focus on NNB GenCo's organisation of lifting activities (Regulation 8) and thorough examination and written schemes (Regulation 9). This will align with NNB GenCo's intention to complete commissioning for construction and allow installation of the RPV. It must have these items in place ahead of any use of the polar crane.