The purpose of this intervention was to inspect that EDF Energy Nuclear Generation Limited (NGL), as Licensee, is exercising adequate oversight and control over the supply chain involved in delivering equivalent spares to nuclear power stations, so that nuclear safety is assured. This intervention is in accordance with the planned inspection programme contained in the Hartlepool Integrated Intervention Strategy (IIS) for 2018/19.
The intervention was carried out by me, a specialist supply chain Inspector, and ONR’s corporate inspector for NGL.
“Equivalent” spares are ones that are evaluated to be equivalent to the capability of the spares specified by the original equipment manufacturer.
The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.
The intervention was in three parts:
The intervention was undertaken against Licence Condition (LC) 17 for the management system in relation to equivalent spares.
As this was not a Safety System Intervention, no judgement was given.
I found that there was a documented, adequately resourced and controlled system in place for management of equivalent spares which is designed to operate fairly autonomously at each Power Station with oversight and support at Fleet level. This is in line with NGL’s operating model.
At Hartlepool, I found evidence that the system is embedded and working effectively in accordance with its intent. There was consistency between local and Fleet-level interpretations of how the system should operate. There were some minor deviations and areas for improvement discovered, which were confirmed in writing to the Station.
I followed the records of one example of an equivalence decision important for nuclear safety from the Station to the first tier supplier, Cavendish Nuclear, in order to test the adequacy of the supplier’s own arrangements. I found that the staff involved had suitable prior experience and access to appropriate specialist advice; although the document describing the arrangements required comprehensive review and revision. I have raised this with Cavendish Nuclear and NGL so that it can be addressed promptly, systematically and followed through to completion by them. I have raised a regulatory issue to track this.
Overall, I judge that a green inspection rating against LC17 is appropriate for Hartlepool, because the management system for equivalent spares is appropriate and is implemented effectively at station. The shortfalls identified were related to the suppliers procedures and documentation which were minor in relation to nuclear safety management and when compared to appropriate benchmarks.
I conclude, based on evidence from interviewing staff, reviewing procedures and following records, that NGL is exercising adequate oversight and control over the supply chain involved in delivering equivalent spares.
I have raised a regulatory issue to ensure that the review and revision of procedures at Cavendish Nuclear is tracked to conclusion. No additional regulatory action is considered necessary beyond routine interactions with NGL.