ONR expects that the Licensee and its suppliers should have people in place who are competent to perform their roles, and that they actively manage their competence using adequate arrangements.
This intervention is focussed on gather evidence on whether the Licensee, NNB Generation Company (HPC) Ltd (NNB), has adequate arrangements for defining, specifying and overseeing competency expectations within their supply chain.
The purpose of the intervention was to gather evidence on:
NNB’s arrangements for specifying competency requirements in the supply chain;
ONR visited the offices of NNB and one of their Tier 1 suppliers, PALL. We held discussions with relevant NNB and PALL personnel about the competence management arrangements, and examining various records. PALL are designing, manufacturing and supplying filters for the Hinkley Point C facility.
NNB has arrangements for specifying competence requirements in its supply chain. The arrangements include a minimum expectation that suppliers will be accredited to ISO 9001, which has a section requiring competence management to be in place. At certain stages in the procurement of items, including invitation to tender and pre-qualification, NNB have the opportunity to define competence expectations. For the PALL contract, competence expectations were defined by reference to experience in the design code RCC-M, which drives particular competence requirements for welders of pressure vessels.
During the procurement process, any competence expectations are defined and (subsequently) checked on NNB’s behalf by EDF SA Responsible Designer (RD), with NNB exercising some intelligent customer oversight through readiness reviews and their gateway system. ONR is conducting other work under its intervention plan to examine NNB’s approach to being an intelligent customer for specifications.
We found evidence that NNB takes steps to assure themselves that their suppliers have arrangements in place for maintaining and demonstrating the competence of their staff. A quality audit of the supplier was done before signature of the contract, and a supply chain assessment report, which includes a section on competence management, was done after contract award. For suppliers of services, NNB said that they can directly assess competence through interview if necessary. At PALL, a routine visit by NNB to oversee manufacturing did include verification of competence records for welders involved in the build.
PALL is a Tier 1 supplier to NNB. We verified that their competence management arrangements operate satisfactorily in practice, although some improvement is necessary, particularly to track competences of individuals in PALL to the specific needs of the NNB contract. PALL had these improvements underway and are aiming to complete by December 2019. In addition, NNB and PALL need to work together to define the supervisory competencies required for the upcoming site installation phase of the contract.
We found evidence that PALL, as a Tier 1 supplier, cascades competence expectations to its sub-suppliers. NNB and PALL have an agreed list of approved sub-suppliers (to PALL), and PALL implements an audit programme targeted at its sub suppliers, based on ISO 9001 that includes competence management.
Overall, from the sampled evidence, we conclude that NNB has a system in place to define, specify and oversee its competency expectations within its supply chain. Based on the scope of this intervention, we rate this inspection as Green.