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 condition compliance arrangements commensurate to the current stage of the project.
The purpose of this intervention was to assess the adequacy and effectiveness of NNB GenCo’s current HPC site quality function, and the effectiveness of its oversight of the main civil works contractor (Bylor) focusing on the Nuclear Island.
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 NNB GenCo’s current HPC site quality function.
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.
Based on the discussions and evidence provided on 16 and 17 July 2020, ONR concluded that NNB GenCo has delivered improvements in the HPC site quality function, and the effectiveness of its oversight of the main civil works contractor. However, it is acknowledged that further developments are required to deliver increased effectiveness of the respective NNB GenCo and Bylor quality functions.
NNB GenCo provided an overview of its quality management function at the HPC site. Based on the information presented, ONR observed that there has been demonstrable improvements in the control and reporting structure within the function, specifically in relation to the management, escalation and resolution of quality related issues.
ONR noted that there are well defined and structured interactions between NNB GenCo and Bylor. From the evidence provided, examples of collaboration were observed to address improvements in a number of areas, including but not limited to, non-conformance report (NCR) categorisation and trend analysis.
From the records presented, ONR observed that the target timescale for completion of post pour records has been amended from 6 weeks to 12-18 weeks. NNB GenCo confirmed that this change had been formally approved but not communicated to the regulators and was a change in strategy from the LC6 Intervention conducted in September 2019.
From the evidence sampled and discussions held, it is recognised that NNB GenCo has developed and continues to enhance its Quality Performance Indicators and related metrics. However, it was recommended that the process should be further evolved to ensure that there is a clear ‘golden thread’ of quality performance and metrics between NNB GenCo and Bylor i.e. for Life Time Quality Records (LTQR).
Utilising Quality Performance Indicators, NNB GenCo presented evidence to outline the reduction of NCRs / field change requests / requests for information for Unit 2 relative to Unit 1; the enhanced Unit 2 performance was attributed to effective learning and knowledge transfer within NNB GenCo and Bylor.
Overall, ONR concluded that an inspection rating of GREEN, is appropriate. Areas of good practice were highlighted, and although some minor areas for improvement were identified further developments are planned by NNB GenCo and Bylor. It was agreed that the implementation of these developments will be monitored through future Interventions and meetings.