Executive summary
Date(s) of inspection: October 2024
Aim of inspection
The aim of this inspection was to gain assurance the licensee’s processes and arrangements for integrating equipment into civil structures are adequate and that those arrangements are being implemented on-site in a suitable and sufficient way.
Subject(s) of inspection
- LC19 - Construction or installation of new plant - Rating: Amber
Key findings, inspector's opinions and reasons for judgement made
The inspection findings were as follows:
- There are established processes and arrangements for integrating equipment into civil structures, and those arrangements are being implemented on-site in a suitable and sufficient way.
- There is evidence of NNB GenCo (HPC) and key on-site contractors working together to mitigate the challenges posed by the projects schedule and the resulting installation sequence. However, there is a clear need for improvement in the planning and integration of activities.
- The standards of Foreign Material Exclusion (FME), general asset protection and housekeeping were variable, and improvement is required in several areas.
- Potential areas for improvement with NNB GenCo (HPC) IT tools including SWITCH were observed but areas of good practice were identified in the IT tools of the contractors sampled.
- The application of the project's physical and electronic quarantine arrangements were inconsistent and require improvement.
- The records sampled were generally fit for purpose although several areas for enhanced clarity and consistency were identified.
- Requirements specified by the Tertiary Hold Point Panel had not been effectively tracked and lacked visibility to those on-site and in charge of areas.
Conclusion
NNB GenCo (HPC) and the contractors sampled have established adequate processes and arrangements for integrating equipment into civil structures, and those arrangements have continued to develop since ONR last sampled this area. However, during the inspection an accumulation of shortfalls were identified in relation to the application of quarantine arrangements, foreign material exclusion, the care and maintenance of assets, and the tracking of requirements.
A number of these items have previously been identified as requiring improvement during ONR inspections and are the subject of existing Regulatory Issues. In relation to the RI-11717 (Application of Quarantine Arrangements), ONR expects NNB GenCo (HPC) to have adequate arrangements to effectively identify, segregate and manage quarantined assets. Consequently, given the issues observed during the inspection, ONR will be seeking confidence in the application of the extant quarantine arrangements and the actions being taken in response to the Regulatory Issue, prior to a dedicated ONR inspection of quarantine arrangements in Quarter 1 2025.
On this basis, an AMBER rating was assigned to this inspection and ONR will seek improvement via existing Regulatory Issues.