- Site: Hinkley Point C
- IR number: 22-006
- Date: June 2022
- LC numbers: 17, 19
Purpose of Intervention
The Office of Nuclear Regulation (ONR) conducted an inspection at [Tier 2 supplier’s] manufacturing facilities in Italy to support regulation of the Hinkley Point C (HPC) supply chain.
The inspection covered manufacturing activities for a number of Hinkley Point C heat exchangers. The heat exchangers are being manufactured by [Tier 2 supplier] under a contract from [Tier 1 supplier]. These components were selected for inspection by ONR based on their importance to nuclear safety and taking account of experience from other EPR plant.
The aim of the inspection was to gain confidence in the implementation of the licensee’s arrangements for oversight of manufacturing activities and that the components delivered to site will be fit for purpose in terms of fulfilling safety case requirements. ONR also considered the cascade of culture and learning into the supply chain (multi-tier).
Interventions Carried Out by ONR
The inspection was carried out through an in-person visit to [Tier 2 supplier’s] premises in Italy. The inspection included discussion with the licensee (NNB Generation Company (HPC) Limited – NNB GenCo), and representatives of the Tier 1 and Tier 2 suppliers. ONR inspectors observed manufacturing and testing activities and carried out a sample review of documentation. As part of this, the intervention considered relevant implementation of Licence Conditions 17 and 19 by NNB GenCo.
Licence Condition 17 (LC17) requires that the licensee’s management systems give due priority to safety so that any actions or decisions taken do not have an adverse effect on safety. It also requires the licensee to apply quality management principles to all activities that may affect safety. This includes those associated with the procurement, design, construction, manufacture, commissioning, operation and decommissioning of the installations on the site including the preparation and review of safety documentation.
Licence Condition 19 (LC19) requires a licensee to make and implement adequate arrangements to control the construction or installation of any new plant which may affect safety. This should include effective oversight of the supply chain for systems, structures and components manufactured off the construction site.
The inspection utilised the following ONR guidance:
- NS-INSP-GD-017 – LC17: Management Systems
- NS-INSP-GD-019 – LC 19: Construction or Installation of New Plant
- NS-INSP-GD-070 – Safety Culture Guide for Inspectors
Explanation of Judgement if Safety System Not Judged to be Adequate
Key Findings, Inspector’s Opinions and Reasons for Judgements Made
We carried out a walkdown of the manufacturing facility from goods receipt through welding, machining, inspection and non-destructive examination. We were satisfied that the manufacturing facilities were suitable. We considered that [Tier 2 supplier’s] workers had a good level of technical knowledge of the manufacturing process and the significance to nuclear safety.
We noted a positive nuclear safety culture and a commitment by [Tier 2 supplier’s] managers and workers to produce high-quality components.
We sampled the surveillance carried out on behalf of the licensee and tier 1 supplier. We were satisfied that NNB GenCo was providing effective oversight of [Tier 2 supplier’s] manufacturing activities.
Conclusion of Intervention
Based on the evidence sampled we concluded that:
- NNB GenCo is providing adequate oversight of the manufacturing activities carried out by [Tier 2 supplier].
- We gained sufficient confidence that the heat exchangers manufactured by [Tier 2 supplier] will be fit-for-purpose in terms of fulfilling safety case requirements.
- There was an adequate cascade of culture and learning from the licensee into its supply chain for the components sampled.
We therefore concluded that an overall inspection rating of Green (No formal action) was appropriate against LC17 and LC19.