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 if NNB GenCo has adequately implemented its management system arrangements for manufacturing non-conformance.
This was a joint ONR and NNB GenCo Independent Nuclear Assurance (INA) intervention.
ONR conducted a Licence Condition (LC) 17 (Management Systems) compliance inspection targeted on the NNB GenCo quality management arrangements. This involved sampling the adequacy of the NNB GenCo management system arrangements for manufacturing non-conformance.
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.
ONR acknowledged that NNB GenCo has identified a number of specific improvements and actions to address gaps and shortfalls in its management system arrangements for managing manufacturing non-conformances. Based on the evidence presented, ONR observed there was no single or overarching plan which summarised the totality, responsibility and timescales for the delivery of improvements.
ONR noted the creation of a specific non-conformance report (NCR) management team and reinstatement of the manufacturing NCR oversight group, which when fully operational should contribute to drive efficiencies and influence the development and delivery of the required improvements for the manufacturing NCR processes.
The demonstration of Consolidated Change Information System (CCIS) using current training materials provides confidence that there is a system in place ready for the recording and monitoring of all manufacturing NCRs. However, NNB GenCo acknowledged that the roll-out of training and level of usage needs to increase in the coming months.
The current NCR management team’s roles and responsibilities, including the use of the CCIS tool, are not reflected in the current NNB GenCo processes for managing NCRs. NNB GenCo advised this is to be addressed within the next two months.
NNB GenCo believes that there is clarity on the contractual arrangements for manufacturing NCR management at tier one and tier two contractor level. There was less clarity on the required scope of manufacturing NCRs which are required to be processed and managed on CCIS.
ONR noted there appears to be an underestimation of the duties and the impact of being the owner of the manufacturing NCR CCIS system where the system is holding the primary records about equipment non-conformances that may be required for the life of the power station (approximately 65 years).
NNB GenCo is considering re-evaluating the availability and competence of categorisers within the quality function. However, based on the evidence presented, ONR considers improvements are required in the current arrangements for the NNB GenCo oversight of manufacturing NCR categoriser training and approval.
ONR raised a number of observations on manufacturing NCRs provided by NNB GenCo in support of this intervention. The observations will inform ONR’s regulatory response to this intervention and broadly relate to the completion and adequacy of supporting evidence, timeliness and closure of manufacturing NCRs, and categoriser training and approval.
NNB GenCo’s arrangements for managing manufacturing NCRs contain some gaps and shortfalls. Although areas of good practice were identified and improvements are planned, based on the selected samples examined and discussions held, NNB GenCo’s current LC 17 arrangements for the management of manufacturing NCRs were not found to be adequate and require improvement. We have therefore assigned a rating of AMBER to this intervention.
ONR will consider a proportionate regulatory response to the findings from this intervention, including similar findings from other ONR related interventions, after further planned related interventions have been completed over the next few months.