Executive summary
Date(s) of inspection: November 2024
Aim of inspection
The aim of this inspection was to sample NNB GenCo's arrangements for care and maintenance of:
- Equipment delivered to its on-site and off-site storage facilities; and,
- The implementation of these for electrical and mechanical equipment.
Subject(s) of inspection
- LC6 - Documents, records, authorities and certificates - Rating: Green
- LC17 - Management systems - Rating: Green
- LC28 - Examination, inspection, maintenance and testing - Rating: Green
- Provision and Use of Work Equipment Regulations 1998 (PUWER) - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
My inspection sampled four on-site storage compounds and two off-site warehouses. The purpose of this was to judge the adequacy of NNB's arrangements for the conduct and supervision of care and maintenance of equipment important to safety when in storage.
At the off-site warehouses, although the care and maintenance arrangements are continuously maturing and developing, I did not identify any significant gaps in relation to the conduct and supervision of care and maintenance. The arrangements that are in place, both at Wincanton (when conducting passive maintenance) and those utilised by NNB GenCo’s teams (when conducting active maintenance) are satisfactory and being applied implemented.
For the on-site storage compounds, it was more difficult to judge the adequacy of the implementation, because there were fewer items in those compounds under care and maintenance. However, of those I did sample, I did not identify any issues with the application of the arrangements.
I did note several minor shortfalls, where improvements are needed. For these I provided observations and advice. The areas of note were:
- NNB GenCo had altered the care and maintenance requirements for a pump sampled. It was not able to demonstrate traceability of agreement to this change, or that the Care and Maintenance Plan had been updated to reflect the revised position.
- Within its arrangements, NNB GenCo does not specifically undertake a review, with the manufacturer, of the Care and Maintenance Plans where storage extends beyond the originally planned period. Some items are now expected to be stored for several years rather than months.
- Each compound or supplier, on-site and at the off-site locations all appear to use different arrangements for quarantine, with varying amounts of information captured. This does not align with the respective management arrangements or relevant good practice.
For the above areas concerning care and maintenance plans I undertook a separate Level 4 meeting, post-inspection, to discuss them further with NNB GenCo. During this meeting, NNB GenCo took three actions for it to review and if necessary revise its arrangements.
In relation to quarantine arrangements, ONR has an existing Level 3 Regulatory Issue (RI-11717) concerning on-site arrangements. After speaking to the inspector responsible for closure of the RI, I am content that the existing actions can be utilised to seek improvement in the arrangements for off-site quarantine, and consistency across off-site and on-site arrangements.
Conclusion
Although there were a number of minor shortfalls, resulting in observations and advice given, there was nothing that I judged to be a significant breach of regulatory requirements or of NNB GenCo’s own arrangements. For this reason, I have rated the inspection GREEN.
I consider that those minor shortfalls concerning how NNB GenCo is managing the extended storage of assets, requires further engagement. The scope of this engagement will seek confidence that equipment important to safety, whose storage has or will exceed planned periods, is clearly identified, the ongoing NNB GenCo engagement with manufacturers, and how modifications to care and maintenance plans are agreed with stakeholders, recorded and implemented.
Consequently, I held a Level 4 (technical) meeting with NNB GenCo on 20 November 2024 (post-inspection) to discuss this further. I placed three actions on NNB GenCo which involved it reviewing its current arrangements and performing a review of contracts and equipment to determine whether the issues raised impacted other areas. NNB GenCo committed to complete the three actions by 17 January 2025. Consequently, I am not proposing to raise a Regulatory Issue as it is already being actioned. However, if the deadline is not achieved, then I will review my position.
ONR will further inspect arrangements across the site next year, during which improvements to the items identified will be sampled.