Date(s) of inspection:
- January 2023
Aim of inspection
ONR’s focus to date has been on the assessment of NNB Generation Company (HPC) Ltd’s (NNB GenCo’s) arrangements for specification of equipment qualification (EQ) requirements for safety related equipment. NNB GenCo has let a number of contracts and is undertaking surveillance of these, including the qualification activities.
The aim of this inspection was to gain confidence in the practical arrangements in respect to equipment qualification and its preservation prior to installation.
To do this, ONR inspected NNB GenCo’s arrangements for:
- observation of tests and confirming that EQ requirements are met for safety classified systems and components;
- the receipt, handling and storage of qualified equipment within its stores;
- quarantine of equipment awaiting qualification, for example completed qualification reports; and
- preserving EQ of equipment within the stores, that is maintaining an appropriate environment and applying appropriate examination, inspection, maintenance and testing (EIMT) activities.
The purpose was to gain confidence:
- in the implementation of NNB GenCo’s EQ programme and evidence; and
- that equipment is stored and EQ is preserved in accordance with modern standards and guidance prior to installation.
My inspection was based on four Licence Conditions below. I made use of relevant good practice, noted within the following guidance:
- NS-INSP-GD-006 Licence Condition 6 (Documents, records, authorities and certificates)
- NS-INSP-GD-017 Licence Condition 17 (Management systems)
- NS-INSP-GD-019 Licence Condition 19 (Construction or installation of new plant)
- NS-INSP-GD-028 Licence Condition 28 (Examination, inspection, maintenance and testing)
- IAEA Specific Safety Guide SSG-69 Equipment Qualification in Nuclear Power Plants
- EPRI Nuclear Power Plant, Equipment Qualification Reference Manual
In addition, I also had the opportunity to review whether individuals were suitably qualified and experienced during the inspection. This was judged against ONR’s guidance on Licence Condition 12 (Duly authorised persons and other suitably qualified and experienced personnel), however it was not rated as it was not originally part of the inspection scope or planned.
Subject(s) of inspection
- LC 06 – Documents, records, authorities and certificates – rating: Green
- LC 17 – Management systems – rating: Green
- LC 19 – Construction or installation of new plant – rating: Green
- LC 28 – Examination, inspection, maintenance and testing – rating: Green
Key findings, inspector’s opinions and reasons for judgement made
The inspection provided me with appropriate confidence that NNB GenCo’s arrangements for surveillance of testing, and verification and validation of completed test documentation were adequate, aligning with relevant good practice. The inspection also found that the implementation of arrangements within the stores, in particular undertaking and recording evidence of care and maintenance of qualified equipment, aligned with relevant good practice.
A number of observations were made, where I judged NNB GenCo could make improvements to its arrangements. These were:
- Undertaking periodic assessment of the adequacy of the equipment qualification programme. Currently there is no evidence that NNB GenCo does this.
- Inclusion of equipment qualification training for those involved in activities relating to storage and preservation, that is, care and maintenance activities.
- Identification of shelf-life for all stored components. NNB GenCo should also make improvements it identified for its management system in relation to adequately recording the packing date and monitoring the shelf-life of stored components.
- Consistency in securing labelling identifying where equipment is under investigation to the packaging and recording on the labelling the due date for those investigations. This will help ensure the label remains with the correct package and that it is easy for personnel to identify when a due date has expired.
These observations were judged to be minor in respect to the overall equipment qualification arrangements. Therefore, I judge that they do not warrant tracking through a regulatory issue. I will monitor NNB GenCo’s assessment of the adequacy of its qualification programme through future level 4 technical meetings, along with training and monitoring of shelf-life. The labelling observation is one that NNB GenCo had already committed to addressing.
I was able to gain an appropriate insight into NNB GenCo’s application of arrangements in relation to equipment qualification and its preservation during storage, prior to installation. Overall I judge NNB GenCo’s implementation of its arrangements to be rated Green. This is because relevant good practice was generally met, with only minor shortfalls identified when compared with appropriate benchmarks.
In relation to compliance with specific licence conditions, I judge NNB GenCo’s activities for preservation of equipment qualification as Green for:
- Licence Condition 6 (Documents, records, authorities and certificates)
- Licence Condition 17 (Management systems)
- Licence Condition 19 (Construction or installation of new plant)
- Licence Condition 28 (Examination, inspection, maintenance and testing)