This Chief Nuclear Inspector's (CNI) Inspection was established following shortfalls identified at Areva's Creusot Forge (ACF) facility, one of NNB GenCo (HPC) Ltd's (NNB GenCo) key suppliers. The shortfalls challenged the adequacy of NNB GenCo's supply chain management arrangements, including the effectiveness of their supply chain oversight and assurance arrangements.
ONR had previously participated in a multinational inspection of ACF during November/December 2016, led by the French Nuclear safety Regulator, Autorité de Sûreté Nucléaire (ASN) as part of the Multinational Design Evaluation Programme (MDEP). The MDEP, Vendor Inspection Cooperation Working Group (VICWG) had targeted the ACF facility due to regulatory concerns regarding historic product record irregularities. The MDEP inspection identified shortfalls in Areva's quality management arrangements and the adequacy of their corrective action plan.
As a result of the shortfalls, a targeted Level 1 meeting was held with NNB GenCo in February 2017, and was considered an initial step in rebuilding confidence in NNB GenCo's Intelligent Customer arrangements. NNB GenCo subsequently wrote to the CNI detailing their improvement action plan and associated governance arrangements (TRIM 2017/85011).
ONR committed to a future Level 1 meeting prior to the end of the 2017/18 financial year and the CNI identified that a supply chain focussed CNI's inspection would be deployed to inform the engagement.
The purpose of this supply chain focussed CNI's inspection was to assess the adequacy of NNB GenCo's supply chain management arrangements including oversight and assurance and improvement action plan, specifically focussed on:
This targeted CNI Inspection, in the early stages of NNB GenCo's construction and manufacturing programmes, gave ONR the opportunity to assess the project's supply chain management arrangements and reinforce its regulatory expectations. The timing allows NNB GenCo to respond as required to any identified shortfalls prior to the acceleration of HPC construction and manufacturing activity.
The CNI's Inspection scope was defined on an approved project task sheet (TRIM 2017/313658).
As described in ONR Guide ONR-INSP-GD-059 Rev. 5, CNI inspections differ from more routine ONR inspections in that they are specifically identified and commissioned by the CNI. The purpose of the inspection is to inform the CNI's position on a specific regulatory matter that is of a strategic nature, for example, having high current or potential safety or security significance, or having the potential to adversely impact public confidence.
A CNI Inspection will usually involve engagement at a senior level and may involve multiple sites and duty holders, as well as other stakeholders with an interest in the matter being inspected. It may, as in this inspection, include visits and engagements internationally.
This CNI's inspection had four interconnected elements, commencing at ACF and progressing to the HPC site to assess the effective deployment of lessons for NNB GenCo's other key contractors. The four elements of the inspection were conducted on the following dates:
The outcome of each inspection was recorded in individual Contact Records enabling the full conclusions and judgements of the CNI inspection to be recorded on this overarching Intervention Record.
Throughout this CNI's inspection, themes have emerged that relate to both improvements in NNB GenCo's processes and to shortfalls in management system arrangements that, if unresolved, have the potential to affect safety.
Initial conclusions and judgements were formed by the ONR inspection teams after each inspection element. Any preliminary findings identified during these inspection elements were subsequently considered collectively on completion of the whole inspection scope, and where regulatory shortfalls were identified, Regulatory Issues have been raised.
I have analysed the key findings and judgements of this CNI's inspection and consider that they can be most appropriately defined against the six themes identified in the sections below.
Section 1.4.1 reflects positive progress made by NNB GenCo and its key supplier Areva and therefore no associated Regulatory Issue has been raised. However, I will raise an associated Regulatory Issue as appropriate for each of the themes in sections 1.4.2 to 1.4.6, to define the required improvement activity.
The scope of the CNI inspection was specifically targeted at supply chain management and associated areas. NNB GenCo is currently undertaking work associated with design, construction and early manufacturing activities. Although arrangements for control of quality are judged, through ONR's wider regulatory activities, to be appropriate at present, this inspection has identified a number of areas where improvements are required to ensure this position is robustly maintained as the project progresses and the volume of work and resources required increases.
The CNI's inspection placed emphasis on the adequacy of enhanced arrangements at ACF. The inspection team concluded that ACF and NNB GenCo had made good progress in deploying their improvement programme and had enhanced their manufacturing processes, management system arrangements and the facilities' nuclear safety and quality culture.
Overall, I am broadly satisfied with the enhanced management system arrangements. I note however, as the improvement programme is not yet fully deployed, ACF's enhanced arrangements have yet to be fully embedded and therefore will require continued drive and appropriate oversight and assurance from NNB GenCo as the Intelligent Customer for the products supplied by ACF, in order to be demonstrated as sustainable over the longer term.
The enhanced arrangements included evidence of strengthened assurance activity within NNB GenCo's Manufacturing, Inspection and Testing (MIT) function, and EDF Group's CEIDRE (Centre d'Expertise et d'Inspection dans les Domaines de la Realisation et de l'Exploitation) manufacturing inspection department, that will be essential as the equipment manufacturing programme accelerates as the project progresses.
I recommend that ONR continue to assess NNB GenCo's and Areva's progress through the existing ‘Areva Manufacturing' regulatory workstream.
Evidence was not provided during the inspection to demonstrate how NNB GenCo had captured all the key learning from the issues associated with the failings at ACF, and ensured its effective promulgation to NNB GenCo's key contractors interviewed as part of this inspection. I did however recognise that evidence was available of the learning for site contractors from the similar issues associated with First Nuclear Safety Concrete (FNSC) substitution concrete pour.
The CNI Inspection scope emphasised that it would consider the effective deployment of lessons for other key contractors. Therefore, I consider it important that NNB GenCo evaluate how it has captured the key learning from the shortfalls at ACF and consider if it has been effectively promulgated within its organisation and its key contractors.
I consider that NNB GenCo's improvement plan, derived from of its supply chain self-assessment, requires further development as the version provided to the ONR inspection team was not effectively prioritised, time bound, resourced and aligned to the HPC construction schedule and agreed regulatory permissioning points. I am of the view that this version is not adequate given that improvement activities relate to shortfalls in management system arrangements which, if unresolved, have the potential to affect safety.
Furthermore, I consider that the improvement plan should be subject to appropriate project wide governance and leadership to ensure that it is prioritised on project risks, noting that the existing plan places emphasis on the development of the improvement activities on an individual directorate basis.
This inspection has found shortfalls in NNB GenCo's quality management system arrangements related to supply chain management activity. Some shortfalls were identified during NNB GenCo's supply chain self-assessment activity performed in advance of this inspection. However, this CNI's inspection identified the following management system shortfalls that will require resolution:
Inspection & Test Plans (ITPs) - NNB GenCo has identified that it needs to improve its guidance with regards to the preparation and use of ITPs and that they should be consistently implemented. I consider that this will be beneficial in reducing construction quality risks and should ensure that some of the inconsistencies in implementation identified during this inspection are addressed or subject to a formal NNB GenCo assessment or approval processes.
Internal Assurance Programme - The supply chain self-assessment did not identify shortfalls in NNB GenCo's internal assurance programme, which the CNI's inspection team subsequently identified. The assurance function had not completed any internal process audits during 2017, with no future audit programme available. The lack of an internal process assurance programme was disappointing as an effective programme may have prevented many of the shortfalls identified both in the supply chain self-assessment and in this inspection.
Supply Chain Assurance - The CNI inspection team identified potential risks with NNB GenCo's oversight and assurance arrangements for work sub-contracted by their Tier 1 suppliers at both ACF and with site contractors. I have challenged NNB GenCo to ensure that their approach is commensurate with risk, regardless of where it arises in the supply chain, rather than being focussed on Tier 1 suppliers.
I consider that further development of NNB GenCo's management system arrangements is important to reduce reliance on the competence of individuals to compensate for lack of procedural clarity. This shortfall was highlighted on the construction site related to the ITPs and gaps in project quality documentation. Addressing this should ensure that quality management system arrangements are consistently implemented across the project as it accelerates and the work and number of contractors on site increases.
The CNI inspection team found a lack of clarity over the project wide leadership of NNB GenCo's quality organisation and who had the responsibility for establishing an effective management system and communicating the quality standards, roles and responsibilities across the project to ensure ‘right first time' delivery on the construction site.
I noted during the inspection that NNB GenCo were in the process of reviewing their quality organisational arrangements as part of a wider Management of Organisational Change submission. I consider it important that this change clarifies the roles and responsibilities for quality delivery on the project and enhances the coordination between the site and supporting quality functions.
This CNI inspection has identified shortfalls in supply chain management system arrangements important to safety and roles and responsibilities important to safety.
The supply chain self-assessment completed by NNB GenCo prior to this CNI inspection identified a number of additional shortfalls that require resolution.
Given the conclusions of the CNI inspection, I consider that NNB GenCo should further review its current project assurance arrangements and consider appropriate areas for improvement.
The individual findings from the various elements of this CNI Inspection highlight a number of deficiencies in NNB GenCo's management system arrangements. These individual deficiencies, taken on their own, may not be of such seriousness to raise a regulatory issue; however in aggregation they indicate a broader deficiency in NNB GenCo's arrangements and I judge that overall five Regulatory Issues, aligned with the thematic shortfalls identified above, should be raised.
I have concluded that these Issues represent shortfalls against LC 17 - Management Systems.
Through its wider regulatory interventions, ONR consider that current arrangements, coupled with the competence of personnel, are capable of managing current workscope. However, they may not be sufficient as the project moves forward and work volumes and required resources increase. There is a need, therefore for NNB GenCo to develop these arrangements further to provide sustainable control as the work expands.
The Regulatory Issues identified represent a failure to implement or meet compliance arrangements and therefore I am allocating an Inspection rating of Amber - Below Standard.
This CNI's inspection has achieved its purpose and was efficiently and effectively delivered to plan as defined in the approved project task sheet (TRIM 2017/313658).
The differing elements of the inspection involved a total of eleven ONR inspectors with two ASN inspectors observing while at ACF. The significant number of NNB GenCo and its supply chain staff engaged with as part of this inspection demonstrates the scale, strategic nature and safety significance of the inspection scope.
NNB GenCo has successfully facilitated this inspection with the support of its supply chain ensuring that each element of the inspection achieved its purpose. This involved considerable coordination with ONR in advance of, and during the inspection. I anticipate that this positive support will continue as the issues raised in this inspection are resolved.
The CNI inspection was performed in the early stages of NNB GenCo's construction and manufacturing programmes. The timing will allow NNB GenCo to address the identified shortfalls prior to the acceleration of HPC construction and manufacturing activity.
The inspection has identified five thematic shortfalls which will each be tracked to closure through an associated Regulatory Issue. The resolution of these issues will help mitigate the risk of substandard manufacture and construction quality and potential impacts to the construction schedule and ONR's project permissioning decisions. They may also make a positive contribution to the safe and reliable operation of the HPC Nuclear Power Plant during its operational phase.
I consider that the with the correct application, NNB GenCo will be able to implement the required improvements and close the five Regulatory Issues in advance of regulatory assessments associated with the Nuclear Island Concrete permissioning point currently scheduled for August 2018.
Timely resolution of the identified issues will reduce project risk and contribute to NNB GenCo's aim of quality, ‘right first time' delivery.