Office for Nuclear Regulation

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Level 4 LC21 Commissioning meeting

Executive summary

Purpose of intervention

The Office for Nuclear Regulations (ONR) permissioning strategy for the construction of Hinkley Point C (HPC) includes Licence Condition (LC) 21 'Commissioning as a topic stream under the licence compliance cornerstone theme.

The purpose of the current meeting was for NNB GenCo to provide an update on the preparatory activities for the commissioning phase of the project.

Interventions carried out by ONR

The areas covered by the meeting included:

The Independent Assurance and Compliance Oversight (IACO) Manager attended the meeting on behalf of NNB GenCos safety directorate.

Explanation of judgement if safety system not judged to be adequate

Not applicable; system/structures-based inspection did not take place.

Key findings, Inspectors opinions and reasons for judgements made

The commissioning schedule is now owned by NNB GenCo as opposed to the Responsible Designer (EDF CNEN). This schedule has been integrated into the overall project schedule and is driving system erection completion dates to support the planned commercial operation date for HPC unit 1.

I am satisfied that the commissioning team is continuing to support procurement with a focus on the review of contract requirements and tender return reviews. The team is also engaged with the Areva and Alstom early contractor involvement work being undertaken in advance of the final investment decision.

I consider that NNB GenCo is receiving, and making appropriate use of, commissioning Operational Experience (OPEX) from other EPR projects. However, NNB GenCo agreed to consider how the lack of an auditable record of the OPEX received and what, if any, actions have been taken can be addressed.

I am satisfied that both of the ONR Issues I raised during the review of HPC Pre-Construction Safety Case (PCSR) 2012 Chapter 20 'Commissioning will be addressed in PCSR3.

It was agreed that the commissioning forward work plan would be updated to reflect the key activities/ deliverables included on the project schedule for the next two years; this will assist me in preparing the task sheet for the ONR commissioning intervention.

I am satisfied that the commissioning group is interfacing with other functions within NNB GenCo to ensure that the necessary arrangements are in place to support commissioning activities later in the project.

NNB GenCo confirmed that there is no commissioning input planned for the shadow hold point scheduled for later in the year.

Conclusion of intervention

I am satisfied that NNB GenCo continues to make good progress in terms of the early preparatory/planning work for commissioning. The commissioning team has a good understanding of what is needed as the project moves forward and is interfacing with other functions within the project to ensure that the necessary arrangements are in place to support the commissioning phase.

During the meeting a 'Green RAG (red/amber/green quality indicator) status was agreed.

Two ONR Issues (level 4) were raised during the meeting which will be progressed at future level 4 meetings.

Recommendations

The ONR topic stream lead should carry on monitoring developments in the LC21 work area to ensure that NNB GenCo maintains adequate progress with preparatory work for commissioning and continues to take advantage of the opportunity to learn from other EPR construction projects.