This intervention was for ONR to observe NNB’s progress with their plan to address Regulatory Issue 7042 for Lifetime Quality Records (LTQR). It was for ONR to gain assurance that NNB’s plan is on target to deliver sustained compliance.
Licence Condition (LC) 6 requires the licensee to retain adequate records. LTQR are a subset of these. This is to ensure that safety documentation, design and construction information are available throughout the life cycle of the plant. This information is required to support the safety justification for future commissioning and operation.
ONR communicated to NNB Level 3 Regulatory Issue 7042 in April 2019. The issue was that NNB was not adequately managing their contractors’ provision of LTQR. ONR used the regulatory issue to set a number of expectations. In response NNB produced an improvement plan. This intervention focused on progress with that improvement plan.
NNB has assigned the Quality Strategy Manager to lead the LTQR Improvement and produced a plan to respond to ONR’s regulatory issue 7042. The Quality Strategy Manager is committed to deliver a robust solution. He has escalated his concerns and has sought additional resource to deliver the plan. ONR also observed these NNB good practices:
However, ONR’s intervention has shown that NNB are behind their improvement plan. NNB has not communicated their LTQR specification to all their contractors. As a result, a number of relevant contractors do not have a detailed contract specification for LTQR. We consider that this is evidence that the wider NNB organisation has not made contractual specification of LTQR a sufficient priority.
For current construction work, NNB’s contractors’ delivery of LTQR is behind plan. The delay is partially a result of contractors delivering below standard records. In response, NNB will reissue their LTQR contract specification to include partitioning and improve the sequencing of document delivery. We consider that this response is appropriate.
The LTQR plan delays have impacted other actions in response to the regulatory issue. We consider this is a risk to NNB sustaining their LTQR improvements.
ONR took confidence from the capability and commitment of the Quality Strategy Manager. However, ONR judge that NNB has not made sufficient progress responding to Regulatory Issue 7042 for Lifetime Quality Records (LTQR). Therefore, we have rated this intervention AMBER.
ONR considers NNB’s current improvement plan to be appropriate. ONR will review NNB’s overall LC 6 compliance following the completion of the other relevant planned interventions.