The manufacturing hub is part of NNB Generation Company (HPC) Limited’s (NNB GenCo) arrangements for supply chain management. The hub exists to coordinate the various oversight activities required by NNB GenCo for equipment supplied to it. These activities underpin nuclear safety.
The purpose of this intervention was to check that the hub is in place and working and that the arrangements coordinated through the hub for NNB GenCo to oversee its manufacturing assurance contractor are in place and working.
The intervention complements other Office for Nuclear Regulation (ONR) activities focused on NNB GenCo’s oversight of manufacturing. Taken together, these aim to give ONR confidence that NNB GenCo has adequate arrangements for the oversight and quality of current manufacturing of safety structures, systems and components for Hinkley Point C. The intervention relates to Licence Condition (LC) 17. LC17 requires the licensee to establish and implement management systems which give due priority to safety.
ONR worked with NNB GenCo’s Internal Nuclear Assurance (INA) function on this intervention over two days.
On day one, the ONR and INA team held a discussion around the hub’s purpose, organisation, operation and development; this was led by NNB GenCo, with contributions from other key parties involved in delivering the hub capability. NNB GenCo provided case studies of live contracts to draw out aspects of how the hub currently functions.
On day two, the team engaged with managers from Direction Industrielle (DI), who are NNB GenCo’s manufacturing surveillance contractor. DI delivers certain oversight activities for NNB GenCo coordinated via the hub, and is a key party present at the hub location in Paris.
Since May 2019, a transformation plan has delivered leadership for the hub and produced documents to articulate its purpose, philosophy and ways of working. Consequently, the hub (as a management entity) is clearly in place and supported by senior NNB GenCo and DI managers.
The hub is part of the arrangements to oversee supplier activities, from the point of signature of contract with a supplier, to delivery to site of the equipment. The hub approach is to set out what should be in place at certain stages during production, and document who should be involved and what records they should produce to progress past a stage. This is the “pre-requisite model” for the hub, and is strategically sound as a method to coordinate and control various oversight and control activities.
NNB GenCo has project managers who are responsible for delivery of each contract to quality, schedule and cost, and many of NNB GenCo’s suppliers are currently manufacturing safety systems, structures and components for Hinkley Point C. With this in mind, there is a need for NNB GenCo to make the hub approach mandatory and to train project managers (amongst others) in it, so that the organisation clearly articulates, and clearly expects, that the pre-requisite model, and hub approach, should be followed in particular circumstances.
We heard from DI managers about their resources, how they conduct their activities and interact with NNB GenCo staff and other parties via the hub. Their stated goal was to have confidence in quality, in the sense of both the quality of the equipment produced and in the quality management capability of the supplier. NNB GenCo staff, particularly project managers, need to understand this goal, and how DI operates to achieve it, and this should be part of a structured training and briefing programme.
DI expects that their Inspectors at suppliers’ premises will apply standard “Guides” to manufacturing surveillance; and we heard about how operational experience is included periodically in reviews of the suite of “Guides”. Reference numbers for the “Guides” (though not yet the “Guides” themselves) and DI’s own records are becoming more visible to NNB GenCo staff through the recent launch of a share-point tool between the parties. Building upon this will be essential to improve effectiveness and deliver intelligent customer oversight by NNB GenCo.
NNB GenCo and DI have an agreement between them on the principles for manufacturing surveillance called the “UK Addendum”. Building on this, DI has produced surveillance offers for NNB GenCo’s contracts, in which they present a proposal for their surveillance activities based on an analysis of certain features and applying their “Guides”. DI has produced many surveillance offers and submitted them to NNB GenCo for their review and acceptance, which is ongoing for the majority. Consequently, NNB GenCo has few approved surveillance offers in place, and NNB GenCo must address this so that it can demonstrate that it is an intelligent customer for manufacturing surveillance by DI. In the meantime, NNB GenCo and DI said that DI had internal work orders in place for all NNB GenCo contracts and that this would mobilise DI surveillance activity at the suppliers’ premises. However, NNB GenCo should consider whether they need any further mitigation measures for contracts in flight.
Generally, as manufacturing of an item progresses, suppliers create and maintain a key record called the “Follow up Document” (FUD), sometimes called the Inspection and Test Plan. This document records the quality activities applied during manufacture, and the points at which the Client (NNB GenCo) or its contractor (DI) may request the opportunity to witness an activity. The FUD will also include any hold points set by any of the parties involved in manufacture. The way in which DI operates can give rise to them requesting more witness points and hold points on FUDs than its inspectors will actually use. Consequently, FUDs over-marked with DI witness points, that are not then utilised, can give rise to misunderstandings about the extent of DI’s surveillance of an item of equipment. Therefore, as DI work with NNB GenCo on how best to report on their activities, DI should review how they expect their staff to interact with the FUDs.
ONR has concluded that the hub is in place as an entity and has the potential to work systematically and deliver its coordination function. NNB GenCo should make the hub approach mandatory and train staff as part of making the hub effective.
ONR has also concluded that the arrangements coordinated through the hub for NNB GenCo to oversee its manufacturing assurance contractor are mostly in place, but need more effort by NNB GenCo and DI to work systematically and effectively. An effectiveness review in around 6 months would assist.
Over the last few months, whilst the hub arrangements have been improving, manufacturing is underway at suppliers at the same time. Therefore, we conclude that NNB GenCo and DI need to work together to make the hub arrangements work effectively in practice for all the contracts currently (or imminently) in manufacture. NNB GenCo should consider what mitigations are appropriate for those contracts in flight to secure quality and safety in the period until the improvements to the arrangements bed in.
Overall, ONR considers that a rating of amber is appropriate, and will monitor improvements from the licensee through an ONR Issue.