The intervention examined compliance with the relevant aspects of Licence Condition (LC) 21 (Commissioning) as appropriate to the current stage of the Hinkley Point C (HPC) project, recognising that the station is not yet in operation.
The intervention aimed to gain confidence that the implementation of NNB Generation Company (HPC) Limited’s (NNB GenCo) handover processes to take over the plant from the commissioning team were sufficiently progressed for this stage of the project and that there was evidence of sufficient preparation for the transition to the next stage. It also aimed to review NNB GenCo’s pre-operation’s readiness to perform its cross-functional duties in the future stages of the HPC project (commissioning hand-over / operations) and ensure safe and reliable plant operations.
This planned intervention was conducted jointly with NNB GenCo’s internal regulator.
The intervention included a programme of meetings to assess whether the licensee had developed three key aspects associated with the commissioning hand-over to pre-operations: a strategy is in place and is adequate; an implementation plan is in place and is adequate and progress against the plan is adequate.
The following guidance was utilised:
I consider that the work being carried out by the commissioning team in terms of resource strategy, governance, working groups, safety rules application, use of operational experience has set a fundamentally strong pre-cursor for the future hand-over processes. The commissioning team demonstrated a strong joint working relationship with the pre-operations management team. This has meant that there is good understanding across the teams in terms of their roles and responsibilities.
I found that the planning and the understanding of the training requirements were appropriate for this stage of the project. In terms of training delivery in support of LC21, I found that the current rate of training delivery should be assessed against the programme needs to ensure appropriate pace is maintained. This will ensure that targeted training, as well as the generic training requirements, is undertaken by the commissioning engineers. NNB GenCo was able to demonstrate its plans to ensure an effective training programme delivery via utilisation of the Nuclear Skills Alliance and pre-operations Training Assurance.
I observed a good level of learning from experiences from previous commissioning activities in other light water reactor projects such as Sizewell B, Taishan and Flamanville 3.
I considered the change in the site’s risk profile during the commissioning activities and how this may impact the emergency preparedness organisation. This is an area where an enhanced approach to the emergency preparedness organisation is likely to require additional skills in preparation for these activities.
I judge that for this stage of the HPC project, an overall inspection rating of GREEN is appropriate. I consider that there was sufficient evidence to show an adequate strategy for the commissioning and pre-operations handover was in place. I also consider that there was adequate implementation of the arrangements for this stage of the project and that the progress and preparations for the transition to the next stage of the project were suitably managed.