Office for Nuclear Regulation

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MSC44: Non-Conformance Reporting - Post Design Approval Non-Conformance Reports (NCRs)

Executive summary

Purpose of Intervention

In accordance with the Office for Nuclear Regulation’s (ONR’s) Hinkley Point C (HPC) Construction inspection plan, ONR performs a series of planned compliance inspections of identified licence conditions, to ensure that NNB Generation Company (HPC) Ltd (NNB GenCo) is proportionately and adequately developing and implementing its licence compliance arrangements commensurate to the current stage of the project.

This purpose of this intervention was to assess if NNB GenCo has developed and implemented an adequate quality management process to manage errors in design that are identified after the design has been approved.

Interventions Carried Out by ONR

ONR conducted a Licence Condition (LC) 17 (Management Systems) compliance inspection targeted on the NNB GenCo quality management arrangements. This involved sampling the adequacy and effectiveness of deviations or non-conformances in the design process.

ONR assessed NNB GenCo’s LC arrangements against relevant good practice, which included ONR regulatory guidance, specifically relevant Technical Inspection Guides and Technical Assessment Guides.

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

Based on the discussions and the evidence provided on 19 June 2020, ONR concluded that improvements are required to NNB GenCo’s process for managing design Non-Conformance Reports (NCRs) that are detected after the design is approved. However, NNB GenCo had already recognised that improvements are required to its arrangements.

NNB GenCo outlined its NCR management processes. However, upon review of the individual procedures, it was evident that the NNB GenCo procedures do not provide a comprehensive and robust set of actions for managing design non-conformances.

ONR noted that there is a lack of NNB GenCo ownership in the overall oversight of the process and by virtue, there is a heavy reliance on personal interaction and/or meetings for information exchange rather than a formal process. Given the increasing scale of the project, ONR does not consider it feasible for the current arrangements to be sustained in the longer term.

It was observed that there is a significant reliance placed upon the Responsible Designer’s (RD) NCR process by NNB GenCo and, consequently, where the RD undertakes the categorisation of NCRs it did not appear to be fully aligned to the NNB GenCo categorisation guidance in the areas sampled.

From the records presented and sampled, ONR considers that an area for improvement for NNB GenCo consideration is improved timeliness from initial detection of an NCR through to receipt and closure. At present, there is the potential for there to be delays in the process.

From the evidence sampled and discussions held, it is recognised that NNB GenCo has developed and continues to enhance its key performance metrics and indicators to manage the NCR process. However, it was recommended that the process should be further evolved to ensure that the review of outputs and trends includes all relevant NNB GenCo functions to ensure where necessary appropriate actions are considered in response to weak signals and negative trends.  

ONR noted the recruitment of an NCR Manager to be positive and recognised that this should contribute to facilitate the planned enhancements to the NNB GenCo processes and procedures.

Conclusion of Intervention

Overall, ONR concluded that an inspection rating of AMBER, seek improvement, is appropriate. Areas of good practice were highlighted, and ONR acknowledges that further developments are planned. However, based on the selected samples examined, shortfalls were identified in the process to manage post design approval non-conformances.

ONR will consider a proportionate regulatory response to this and other similar findings in this area upon completion of a number of planned related ONR interventions, which will evaluate NNB GenCo’s overall arrangements for managing NCRs.