Executive summary
Date(s) of inspection:
April 2025
Aim of inspection
Licence Condition (LC) compliance inspections are an essential element of ONR's intervention strategy on any nuclear site and consist of a series of inspections, each of which is intended to establish whether Sizewell C Ltd (SZC) and it’s supporting services (hereafter referred to as the licensee), have adequate arrangements in place, and are adequately implementing these arrangements, for compliance with a specific LC.
The aim of this inspection was to establish whether the Licensee has adequate arrangement in place, and are adequately implementing these arrangements for compliance with LC 19 with regards to the construction of the primary circuit components.
The components of interest are the 2 reactor pressure vessels (RPVs) and 8 steam generators (SGs). NNB have stated that the quality improvements at Framatome have not been realised for HPC Unit 2 (U2) components. SZC as intelligent customer must demonstrate it understands the issues and delivers adequate surveillance so that any latent errors impacting structural integrity are identified that demonstrate that risks have been reduced to as low as reasonably practicable (ALARP).
Subject(s) of inspection
- LC 17 - Management systems - Rating: GREEN
- LC 19 - Construction or installation of new plant - Rating: GREEN
Key findings, inspector's opinions and reasons for judgement made
Framatome produces high integrity components intended for Sizewell C nuclear power plant including the reactor pressure vessel, steam generators and pressurisers.
As such, Framatome must have quality arrangements in place to ensure that these components are built so that they cannot conceivably fail.
Additionally, that Sizewell C Ltd (SZC), as Framatome’s client and the Licensee, must have arrangements in place to oversee Framatome’s work to build the components for them.
This is because the safety case for Sizewell C includes certain structural integrity claims that will only be met if the components are manufactured to the right quality standard.
The aim of this inspection at Framatome’s manufacturing facility at San Marcel, France, was to check that Framatome’s arrangements and the Licensee’s oversight under licence conditions 17 and 19, were being correctly implemented for construction of the primary circuit components.
During the inspection, the inspection team sampled several topics, related to the manufacture of one of SZC’s steam generators, which was being built at the time.
The team inspected:
- Quality Management arrangements
- Cascading of SZC’s contractual requirements to Framatome
- Supply chain control arrangements
- Manufacturing procedures, controls and scheduling
- Control of materials and materials testing
- Personnel training
- Management of manufacturing records
- Management of non-conformities
- Counterfeit, fraudulent and suspect items controls
- Manufacturing equipment maintenance and qualification/calibration
- Improvements arising from Framatome’s quality improvement plan
- Learning from previous quality issues
- SZC’s intelligent customer oversight of quality improvements
- SZC surveillance activities to secure quality
Overall, the inspection team was satisfied that Framatome has adequate manufacturing arrangements to enable delivery of components to the highest reliability requirements.
The inspection team was also satisfied that SZC was operating as an intelligent customer and was managing Framatome (its Tier 1 supplier) appropriately, and that both parties were collaborating effectively with adequate LC17 and LC19 arrangements in place.
The inspection team were informed of Framatome’s investment in improved facilities and a larger workforce at the St Marcel factory. The team consider that this transformation project should drive quality improvements within the facility, although like most large scale projects, it will require careful management by Framatome and monitoring by SZC, so that the risk of latent defects is reduced to ALARP. Any latent defects could arise in the component itself or in associated documentation.
Level 4 Regulatory Issue RI-12560 has been raised to address improvements in SZC oversight arrangements during Framatome’s transformation project. I also raised other recommendations for SZC to address these will be monitored by ONR through normal regulatory business.
Conclusion
ONR concluded, from the evidence, that SZC was operating as an intelligent customer and was managing its Tier 1 supplier, Framatome, appropriately and that both parties were collaborating effectively in order to secure the quality of high integrity components being manufactured for SZC.
There were satisfactory arrangements in place and their implementation regarding Framatome’s manufacturing of high integrity components in sampled areas such as:
- Cascading of SZC contractual requirements
- Supply chain control arrangements
- Manufacturing procedures, controls and scheduling
- Controls of materials and materials testing
- Personnel training
- Management of manufacturing records
- Management of non-conformities
- Counterfeit, fraudulent and suspect items controls
- Manufacturing equipment maintenance and qualification/calibration
- SZC’s intelligent customer oversight of quality improvements
- SZC surveillance activities to secure quality
The inspection team were informed of Framatome’s investment in better facilities and a larger workforce at the St Marcel factory. The team consider that this transformation project should drive quality improvements within the facility, although like most large scale projects, it will require careful management by Framatome and monitoring by Sizewell C, so that the risk of latent defects is reduced to ALARP. Any latent defects could arise in the component itself or in associated documentation.
Level 4 Regulatory Issue RI-12560 has been raised to address improvements in SZC oversight arrangements during Framatome’s transformation project.