Office for Nuclear Regulation

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LC17 - MSC09 NNB’s current arrangements for off-site manufacturing oversight and quality

Executive summary

Purpose of Intervention

ONR designed this intervention in order to assess whether NNB GenCo’s current arrangements for manufacturing oversight and quality have adequate coverage and implementation to ensure safety in operation.  The aim was to give ONR confidence that NNB GenCo has adequate arrangements for the oversight and quality of current manufacturing of HPC safety structures, systems and components.

Interventions Carried Out by ONR

ONR carried out the intervention at NNB GenCo’s offices in Bristol over three days, starting after lunch on day 1, and finishing at lunchtime on day three.

Key Findings, Inspector's Opinions and Reasons for Judgements Made

At the end of the intervention, it is the view of the intervention team that NNB GenCo’s arrangements for off-site manufacturing management and oversight require improvement.

The intervention found that there is no overarching articulation of the oversight process from Signature of Contract to Delivery to Site. There are parts of this in place, but there are some areas where it is not apparent that processes exist.

ONR notes that NNB GenCo’s development of a Project Delivery Model tool is a step in the right direction. It sets out the logic and flow of the manufacturing sequence, although this will not fill in the gaps where processes appear not to exist. It may, however, highlight where gaps exist or where existing processes may need updating.

NNB GenCo has contracted its manufacturing inspection activities to EDF SA’s Direction Industrielle (DI). NNB GenCo states that DI’s performance is improving and it plans to increase its oversight of DI’s activities; it is also expecting DI to improve its reporting.  ONR found some additional areas for improvement relating to the effectiveness of NNB’s oversight of manufacturing activities.

NNB GenCo’s contractors are currently manufacturing HPC Safety Systems, Structures and Components. Any improvement to oversight arrangements will take time to implement. Therefore, ONR will ensure that NNB GenCo puts in place suitable short-term risk mitigation measures.

Conclusion of Intervention

ONR has concluded that NNB GenCo’s arrangements for oversight of equipment manufacturing contain gaps and shortfalls. We identified areas of good practice during the intervention and note that improvements are planned. However, we considered that NNB GenCo’s current LC 17 arrangements require improvement for the management of manufacturing quality. We have therefore assigned a rating of amber to this intervention and will be seeking improvements from the licensee.

ONR are proposing to raise a Regulatory Issue for NNB GenCo’s overall management systems shortfalls. Before raising further regulatory issues, ONR intends to complete other planned interventions on NNB GenCo’s management of Non-Conformances and on the arrangements that exist between them and their manufacturing oversight contractor (DI).