Hinkley Point C - To perform combined intervention on NNB HPC project on the subject of quality
- Site: Hinkley Point C
- IR number: 18-005
- Date: May 2018
- LC numbers: 17
Purpose of Intervention
This was an intervention carried out on EDF Energy Nuclear New Build Generating Company Hinkley Point ‘C’ (NNB HPC) of project management systems including the newly formed quality and learning group. Management systems and quality management arrangements are identified in licence condition 17 (LC 17). The intervention objective was to assess the adequacy of quality and learning processes and the wider project management systems for this stage of the project and to obtain objective evidence of compliance.
Interventions Carried Out by ONR
This intervention was carried at the NNB HPC delivery command centre (DCC) Bridge Water House (BWH) in Bristol on 16th and 17th May 2018 and followed a structured agenda, see TRIM:2018/0185652, which covers the project management systems and specifically the quality function.
This intervention was office based with objective evidence being provided from BWH and the construction site when applicable; never the less I consider that a joint inspection at the construction site may be necessary to sample the effectiveness of the implementation of the Integrated Management Systems (IMS).
Key Findings, Inspector's Opinions and Reasons for Judgements Made
The following positive Items were noted during this intervention;
- I consider that the management systems as presented are compliant with LC17 at this stage of the project.
- I now have more clarity on the roles and responsibilities of key quality posts and considered them to be appropriate for a delivery organisation.
- NNB HPC construction project is certificated to, ISO 9001:2015 ‘Quality Management Systems’ and ISO 14001:2015 ‘Environmental Management Systems’ by an accredited external organisation.
- Actions from the 2017 Management review exercise are being proactively managed. I have found this position to be much improved from the 2016 review.
- Overall, there appears to be a drive in reinforcing links between quality and other functions; a number of examples were provided including; joint site and quality briefs, dashboards, etc.
- Lead position has been filled for organisational learning and there are good links with the site for learning and categorising issues raised.
- Findings from the Chief Nuclear Inspector’s (CNI) Inspection relating to quality and internal self-assessment are being managed using a reasonable strategy. A three stage approach is being applied for each action; arrangements required implementation and measuring the effectiveness of the action. I have found this approach to be structured and reasonable.
The following areas have been identified as requiring improvement;
- I have found no improvement in addressing the shortfall in quality leads - this issue was raised in 2017 and during the CNI inspection, resulting in a level 3 issue been raised from this intervention.
- A number of project documents, for example; project definition documents (PgDD) and project definition documents (PjDD) sit outside the integrated management system (IMS) and there was discussion on their control arrangements. A level 4 issue has been raised. I will arrange to sample the marine contract as part of a scheduled intervention of the construction site in quarter 3 of 2018 to assess the adequacy of the control arrangements for these documents.
- I have found that a notable number of process documents including the management systems manual on the IMS portal are outside their review period. I would expect a prompt management response to this shortfall and will review progress during level 4 meetings.
- The IMS portal training completion is below target requirements, management action is required to improvement this situation and identify the root causes to prevent reoccurrence.
- I have been informed that the supply chain and quality improvement management plan (SQIMP) actions/themes are owned by senior post holders rather than process owners. I have asked the Licensee to consider if the process owners as appointed are targeted at the right level as part of their role is procedural improvements.
My judgement is that overall the rating for this work stream DEV 3, quality, remains at AMBER. To achieve green the following actions are pertinent;
Management action is required to address the shortfalls identified in section 5 above.
Conclusion of Intervention
The intervention achieved its purpose and efficiently delivered to the agenda. All staff presented an understanding of their roles, responsibilities and core processes.
I have concluded that that the management systems and quality management arrangements presented are compliant with licence condition 17 ‘Management Systems’. However, I have rated this work stream as Amber due to shortfalls and f issues identified, which will undermine NNB’s arrangements if not addressed in a timely manner.
I have raised two regulatory issues, one on resource plan and the other on work control documents identified as being outside the integrated management system. I consider that with the correct application of these and the identified planned actions, NNB HPC will gain the required improvements.
I have identified that a joint inspection at the construction site will be required to gain objective evidence of management systems implementation.