The purpose of intervention MSC22 was to determine the adequacy of NNB Generation Company (HPC) Limited’s (NNB GenCo) implementation of its arrangements for authorising equipment manufacturing to progress through the shipment to site Gateway for a package of nuclear safety classified valves.
ONR carried out a Licence Condition 17 ‘Management Systems’ intervention related to the shipment to site manufacturing Gateway. License Condition 17 requires the licensee, within its management systems, to make and implement adequate quality management arrangements for all activities that may affect safety. This includes procurement, design, construction, manufacture and commissioning.
The intervention was carried out by observing the shipment to site Gateway review undertaken by NNB GenCo after which a follow up meeting was held to discuss observations and raise questions.
The Gateway review was conducted in a professional manner with an atmosphere that encouraged discussion; a number of the attributes were considered to represent good practice. I am satisfied that the outcome of the review was appropriate, namely that the shipment should not be approved due to several open points that need to be satisfactorily resolved.
A Lifetime Quality Records partitioning strategy has been prepared by the manufacturer supporting the progressive review of records to identify errors early and allow corrections to be implemented in a timely manner. The strategy has been informally accepted by NNB GenCo with sampling of documentation by the quality lead confirming that records are being produced in accordance with the strategy.
A pre-shipment technical review meeting had been held prior to the Gateway review; having sampled the minutes I am satisfied that the review had been conducted in a thorough manner covering the expected areas. The review concluded that there are no anticipated modifications that could require changes to the design intent, no relevant open non-conformance reports and that relevant exemption requests are being managed. A number of emergent issues were identified that will need to be resolved prior to approval of the shipment Gateway.
The Manufacturing Hub pre-requisites dashboard for the valve contract was discussed; on the basis of the discussions and further clarification following the review I am satisfied that the dashboard is being used appropriately to manage the shipment.
Notwithstanding the general adequacy of the manner in which the Gateway review was undertaken a number of areas for improvement were discussed with NNB GenCo during a follow up meeting; it was agreed that the Project Manager would share the feedback with the Quality Department management team so that any learning can be applied across other contracts.
ONR does not intend to observe any further shipment Gateway reviews for the valve package in question since sufficient evidence had been gathered from observing the current review. However, ONR’s quality inspector may choose to follow up on some of the points noted in the context of his wider engagements with NNB GenCo.
ONR observed the shipment to site Gateway review for a package of nuclear safety classified valves and concluded that the arrangements for conducting such reviews had been adequately implemented.
I am satisfied that the Manufacturing Hub prerequisite model is being used appropriately to manage the shipment and that the manufacturer has developed a Lifetime Quality Records partitioning strategy as required by Revision 2 of the specification.
Based on observing the Gateway review, the follow up meeting, sampling of documents and responses received to observations raised I have rated this intervention GREEN, no further action.