Executive summary
Date(s) of inspection: September 2023
Aim of inspection
The aim of the inspection was to ensure that NNB Generation Company (HPC) Ltd's (NNB GenCo) supply chain management systems, and the management systems of its suppliers, are adequately controlling risks from counterfeit, fraudulent and suspect items (CFSI).
The inspection was a series of five targeted inspections of NNB GenCo's suppliers in the UK; primarily tier one contractors, but also some at tiers two and three, together with a series of engagements with Hinkley Point C (HPC) managers responsible for CFSI arrangements.
Each supplier was inspected jointly with NNB GenCo's Internal Nuclear Regulator and to a similar format. The inspection team interviewed managers with a role in the CFSI arrangements, checked documents and records and inspected each supplier's workplace. The suppliers were selected to be representative of the range of UK based companies providing safety related equipment to HPC. Some companies were small businesses, others larger, and all were at different stages of delivery to HPC, although most were in manufacture.
Subject(s) of inspection
- LC 6 - Documents, records, authorities and certificates - Rating: Not rated
- LC 17 - Management systems - Rating: Amber
Key findings, inspector's opinions and reasons for judgement made
Each of the suppliers demonstrated knowledge of CFSI risks, and their impact on safety. There were good practices in place at several suppliers. However, management of CFSI by any supplier includes managing the risks from, and thereby reducing the likelihood of:
- dishonesty and malpractice within that supplier’s own organisation; and
- 'importing' sub-standard items, or receiving unsatisfactory services, from other organisations in relation to that supplier’s final products.
The inspections showed that most suppliers had weaknesses in their arrangements for CFSI against these two areas, with a consequent increase in the risk that counterfeit or fraudulent items could be installed in HPC. The weaknesses were not all present together at any one supplier; but nor was any one supplier without weakness.
The inspectors concluded that, across the suppliers inspected, there was an accumulation of shortfalls and weaknesses in the CFSI arrangements. The inspectors brought those weaknesses together into themes which were discussed with NNB GenCo to action improvements in its arrangements. Themes included:
- errors, oversights and omissions in the completion of Inspection and Tests Plans;
- gaps in training of staff and their awareness of CFSI; and
- policy and procedural shortfalls, some of which could be remedied by NNB GenCo providing clarity on what it expects its suppliers to achieve in relation to certain activities, such as in verifying the authenticity of electronic signatures.
Conclusion
I judge that the inspection should be rated as amber against Licence Condition 17 (management systems) because the evidence from the five suppliers visited, when considered as a whole, points to a significant shortfall by NNB GenCo against relevant good practice for CFSI management.
A regulatory issue has been raised to underpin and monitor an improvement plan developed by NNB GenCo to improve its CFSI arrangements and oversight of its suppliers in this regard.