This intervention was conducted remotely with staff from NNB Generation Company (HPC) Ltd (hereafter referred to as NNB GenCo) and Framatome's manufacturing facility at St Marcel France. It was undertaken as part of the ONR intervention plan, HPC Project Intervention Plan beyond J0.
I conducted a Licence Condition (LC) 19 (Construction or installation of new plant) compliance inspection targeted on the nuclear steam supply system (NSSS). This involved sampling evidence of manufacturing quality at Framatome St Marcel and to inform judgements regarding the adequacy and effectiveness of NNB GenCo's oversight arrangements relating to the NSSS.
Quality improvements are being implemented at Framatome’s heavy manufacturing facilities, the main supplier of the major primary circuit components of the Hinkley Point C NSSS. Regulatory expectations are that NNB GenCo will exercise its intelligent customer responsibilities by satisfying itself that the Framatome improvements are effective such that the required level of quality is achieved.
I assessed NNB GenCo’s LC arrangements against relevant good practice, which included ONR regulatory guidance.
NNB GenCo’s oversight of the Framatome quality management has shown significant recent improvement, through its resumption of review meetings with Framatome and the production of terms of reference for these meetings. From the information that was considered, I believe that there is an observable improvement in some aspects of quality management at Framatome St Marcel. I observed, however, that some of the key performance indicators had not improved significantly compared to the baseline and that some actions on the quality improvement plan were behind schedule.
I observed that the NNB GenCo quality management lead had, during the resumed oversight meeting, identified some shortfalls in Framatome’s quality management but it was not clear as to how NNB GenCo would ensure that these shortfalls would be addressed. In addition, there were no clear actions defined by NNB GenCo in response to the lack of progress of some aspects of the quality improvement plan and the lack of improvement in some of the quality indicators.
Overall I have concluded that an inspection rating of ‘GREEN’ is appropriate for LC19 Construction or installation of new plant. NNB GenCo’s resumption of formal oversight meetings with Framatome along with the issue of terms of reference for these meetings are positive developments. However, improvement is needed in NNB GenCo’s response to adverse findings arising from its oversight of the quality improvements at Framatome St Marcel.
I recognise that, while some improvement is apparent in the management of quality at Framatome St Marcel, some aspects of the improvement plan are behind schedule and that some of the quality indicators have not improved significantly. NNB GenCo should assess the impact of the delays in the quality improvement plan and the trends in the key performance indicators and ensure its conclusions are acted upon by Framatome.
These findings will be used to inform the progress of the level 3 regulatory issue 8037, ‘NNB GenCo quality management arrangements for the HPC primary circuit components manufactured at Framatome Saint Marcel & Creusot Forge’.