Executive summary
Date(s) of inspection:
January 2026
Aim of inspection
This inspection will target how safety case requirements and hazard and operability assessments are effectively implemented in the manufactured chillers. The inspection will also target how the quality of bought-in components is managed, and how the testing of the manufactured components is planned, managed and executed in compliance with relevant regulations.
Subject(s) of inspection
- CDM 15 - Rating: GREEN
- Health & Safety at Work Act, Section 6 (General duties of manufacturers) - Rating: GREEN
- LC6 - Documents, records, authorities and certificates - Rating: GREEN
- LC17 - Management systems - Rating: GREEN
- LC36 - Organisational capability - Rating: GREEN
- Management of Health and Safety at Work Regulations - Rating: GREEN
- Pressure Equipment (Safety) Regulations - Rating: GREEN
- Supply of Machinery (Safety) Regulations - Rating: GREEN
Key findings, inspector's opinions and reasons for judgement made
The inspection was undertaken over two days at two separate facilities at both the manufacturer's offices (J&E Hall Ltd) and at the workshop where assembly took place (Armultra Ltd). This involved detailed discussions related to:
- Quality systems and controls in place
- Care and maintenance
- Management of suitably qualified and experienced personnel
- Management of the supply chain
- Conformity assessment
- Management of cyber security risks
- Obsolescence management
During the workshop visit, the above areas were also sampled together with the management and control of the work areas where the DER and DEQ chillers are manufactured or assembled. I also considered the adequacy of NNB's arrangements in regard to its role as Principal Designer under the Construction (Design and Management) Regulations 2015 and the chiller manufacturer's role as a Designer.
Conclusion
As the inspection was split over two visits, to two dutyholders, the judgements are split between the findings at J & E Hall International, and Armultra Ltd.
In respect to what was inspected at J & E Hall:
Supply of Machinery (Safety) Regulations - the dutyholder provided sufficient evidence to demonstrate its compliance with the regulations, in particular in relation to conformity assessment and declarations of conformity.
Pressure Equipment (Safety) Regulations - the dutyholder provided sufficient evidence that it is utilising a notified body under the regulations and demonstrated that it holds and maintains technical files in support of its conformity assessment and declaration of conformity.
Construction (Design and Management) Regulations - the dutyholder is aware of its duties under Regulation 9 and provided a copy of its design risk register for one of the items within its contract scope. This was reviewed during the inspection and is considered appropriate by the inspector.
Management of Health and Safety at Work Regulations - the dutyholder was able to provide a copy of a risk assessment concerning one of its items of equipment, and demonstrated that this appropriately captures reasonably foreseeable risks in relation to the design, manufacture, installation, operation, maintenance and decommissioning of its equipment. This was judged suitable and sufficient by the inspector.
I raised an observation is relation to the completeness of the End of Manufacturing Report for the Chillers. There appear to be gaps in information, particularly around what qualified weld procedures and which welder ID's performed welding activities on the component parts, for example heat exchangers and valves. For classified components, this is an expectation, but is good practice for other, non-classified components within the nuclear supply chain.
I raised two observations in relation to CFSI:
JEH should consider adding to their training the requirement for Licensees to formally report incidences of CFSI to ONR and therefore the importance of suppliers to report upwards to their Licensees; and,
JEH should reflect on if there is sufficient consideration of at-risk procurement routes and the enhanced inspection and testing needed within their policy and training, to ensure they align with Section 4.5.1 - Procurement management (inclusive of Table 4) of IAEA's Nuclear Energy Series No. NP-T-3.26 Managing Counterfeit and Fraudulent items in the Nuclear Industry.
In respect to the inspection at Armultra Ltd:
There was clear segregation in the workshop in relation to the nuclear related manufacturing and also within the storage facilities.
There was a well established and recorded process for storage and issue of weld consumables.
The manufacturing activities undertaken at Armultra Ltd appear to be well controlled and documented.
It was able to demonstrate that welding activities are carried out by suitably qualified and experienced personnel, and that appropriate records were available.
The contractor provided information in relation to its own supply chain and how and when it undertakes audits of this. Although it was evident that this is carried out, I provided advice to Armultra that it should determine the schedule and frequency of face to face audits in a more risk based approach, rather than location.
The goods inward processes, although they appear to be working, were noted to have opportunities for improvement.
I noted a number of health and safety related issues during the Armultra visit, which were communicated to the dutyholder at the time. These have also been followed up in written correspondence post inspection.
The licence conditions (LCs) do not apply to J & E Hall International or to Armultra Ltd. However, in respect to those within the scope of the inspection and in relation to how it manages its supply chain, the following judgements are made in respect to NNB GenCo (HPC) Ltd:
LC6 Documents - a number of the sampled documentation met ONR's expectations in relation to compliance with legal requirements. One area where a potential shortfall was identified was in relation to records of the qualified weld procedures and welder identification not being present within the End of Manufacture Reports.
LC17 Management System - this was not rated for NNB GenCo (HPC) Ltd. However, there were no adverse findings in relation to those implemented at the contractor organisations.
LC36 Organisational Capability - there was clear evidence that NNB GenCo (HPC) Ltd had the capability to undertake surveillance of its Tier 1 contractors. However, its auditing and surveillance of lower tier contractors was an area that I identified as requiring review. It was apparent during the inspection that NNB GenCo (HPC) Ltd left surveillance and management of the lower tiered suppliers to the Tier 1, without a clear strategy for sampling this.
In relation to NNB's role as the Principal Designer, I judge that NNB GenCo (HPC) Ltd was able to demonstrate that it had appropriate arrangements in place to manage the design and manufacture of the chillers, and that it had appropriate oversight, particularly of it's Tier 1 supply chain that undertakes the design of the sampled chillers.
In accordance with ONR Guidance NS-INSP-GD-064 I judge the rating for this inspection to be GREEN. This is because relevant good practice generally met with minor shortfalls identified, when compared with appropriate benchmarks. These shortfalls have been communicated to the relevant dutyholders.