A new phase for HPC

18 May 2022

Can Hinkley Point C’s construction team step up as the project enters a new phase?

Hinkley Point C construction site pictured in November 2021

Above: Hinkely Point C construction site pictured in November (Photo credit: EDF Energy)


AT THE END OF NOVEMBER last year, the UK’s Office for Nuclear Regulation (ONR) agreed that building work at the Hinkley Point C site could move to the next phase. It is a major step up for the companies involved and for the site itself. So far, most of the activity at Hinkley Point C’s first unit has been around civil construction, but the new phase will mean the workforce will rise to 4000 as a new alliance moves in to install mechanical and electrical components.

Starting the new phase of work of bulk mechanical, electrical and heating, ventilation and air conditioning (MEH) installation does not require a new licence from the regulator but it is referred to as a ‘hold point’ for the construction process. As such, the site operator, NNB Generation Company (HPC) Limited (NNB GenCo) has to present evidence to the regulator that it is ready to move forward.

In its assessment, the regulator said the MEH fit-out was a “major change to the project, and is a mammoth undertaking that will involve simultaneous working on a number of different platforms, employing a large number of skilled and semi-skilled workers, including welders, pipe fitters and electricians.” It noted there had been problems with this phase of construction at Flamanville in France (although those issues had not arisen at a similar project at Taishan in China). The regulator had, however, ‘closed off’ previous concerns over the company’s oversight of off-site component manufacturing.

In this phase, ONR said the adequate supply, training, supervision, and oversight of the workforce throughout the installation period would be a “major challenge”, with many of the workforce new to the industry.

It is not just the workforce that will be new. NNB GenCo has established a joint venture with four existing suppliers (Balfour Beatty Bailey, Doosan, Cavendish and Altrad) in an MEH Alliance (MEHA) to deliver this phase of work over three years. Although the companies involved are very familiar to the industry, the new Alliance will have a new organisational structure designed to deliver this new phase. The regulator said, “arrangements and plans for its [NNBGenCo’s] organisational development including project enablers are yet to be stress tested”.

It is being sure of the new alliance and NNBGenCo’s ‘capability and capacity’ that is ONR’s main aim at this hold point. It wants to have confidence in NNB GenCo to control and oversee the work, so it assessed organisational capability, along with input from the teams overseeing the design and safety case, security and safeguards, site inspection and conventional health and safety.

Keeping tabs on progress

ONR had previously raised concerns over NNBGenCo’s nuclear safety culture and organisational learning, especially after a key member of personnel had left the project. At the ‘hold point’ it had largely closed off those concerns, although it said, “there are still areas relating to NNB GenCo’s nuclear safety culture and organisational learning where further ONR monitoring should be implemented as the project moves into its next phase.”

Similarly, although the ONR was satisfied with MEHA’s capability and readiness for the start of bulk MEH installation, the inspector concluded that “the adequate supply, training, supervision, and oversight of its workforce throughout the installation period will be a major challenge”, both for the Alliance and for NNB GenCo.

The ONR inspectors had previously had concerns over manufacturing, at the ‘hold point’ its views were “generally positive”. It highlighted wider manufacturing issues were noted “which could challenge whether all the equipment delivered to site will be fit for purpose”, but decided not to delay the start of work because MEH activities in the first half-year “are largely limited to the installation of pipe supports, cable trays and HVAC ducting,” allowing for more time to improve confidence in the manufacturing process.

Similarly in the electrical installation, “there will need to be increased ONR focus on cable management and installation practices to ensure that these activities are carried out competently” but that was not a reason to delay the step up.

Although MEHA arrangements were in place for limited work up to now, they are not fully developed for the next phase, ONR said. It expects NNB GenCo “to implement enhanced governance for the first bulk MEH activities, and to take steps to appropriately evolve its processes”

The MEH phase will bring thousands of new workers onto the site but civil construction work will continue well into the MEH installation period. The ONR highlighted that MEH will involve new hazards “associated with multi-trade activities”, such welding and other hot work in restricted and confined spaces, or using portable radiographic sources for in-situ weld checking.

The team says that so far NNB GenCo and the Alliance have implemented appropriate arrangements. But the Alliance will require further development as the scale of activities increases, while NNB GenCo must ensure clarity in the responsibilities for maintenance activities for civil structures once they have been handed over to the MEHA.

After assessing relatively small-scale MEH installation in the non-nuclear island (which had been delayed) with a small number of workers, the report considered the health and safety management and fire safety will need to evolve as the project grows. It says that the scalability of the arrangements is yet to be tested. ONR will keep it under review.

The regulator had found shortfalls in NNB GenCo’s monitoring arrangements, both on health and safety and fire safety audits.

Overall it was clear from the report that ONR still has open questions over whether NNBGenCo and its new Alliance partners can step up fast enough to develop the full capability and capacity needed to deliver the next phase on time. In this case, the ‘stress test’ of the organisation will be happening in real time and the organisation has to pass it.

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