- Site: Hinkley Point C
- Inspection ID: 51673
- Date: September 2022
- LC numbers: 17, 19
Purpose of inspection
The Office of Nuclear Regulation (ONR) conducted an inspection at a pump manufacturer’s facilities in France to support regulation of the Hinkley Point C (HPC) supply chain.
The inspection covered manufacturing activities for the number of HPC safety injection pumps. The pumps are being manufactured, assembled and tested by the supplier in France. 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 examine the adequacy of NNB Generation Company (HPC) Ltd’s (NNB GenCo) implementation of its Licence Condition (LC) 17 and LC19 compliance arrangements to gain confidence in:
- the project’s oversight of the manufacturing of the safety injection pumps by Celeros, including activities undertaken by sub-suppliers;
- the pumps delivered to site will be fit for purpose in terms of fulfilling the safety case requirements;
- cascade of culture and learning (includingcounterfeit,fraudulentand suspect item (CFSI)
- expectations) into the suppliers (multi-tier); and
- management of factory acceptance testing, including licensee oversight.
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.
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.
Subjects(s) of inspection
The following actives were the subject of this inspection:
- Licence Condition 17 – Management systems (Rating – Green)
- Licence Condition 19 – Construction or installation of new plant (Rating – Green)
The inspection was carried out through an in-person visit to the manufacturer’s premises in Annecy, France. The inspection included discussion with the licensee (NNB GenCo) and the manufacturer’s managers and workers. 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 LC17 and 19 by NNB GenCo.
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
We carried out a walkdown of the manufacturing facility from goods receipt through, machining, assembly, inspection, performance testing and packing for dispatch. We were satisfied that the manufacturing facilities were suitable. We considered that the manufacturer’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 the manufacturer’s managers and workers to produce high-quality components.
We sampled the surveillance carried out on behalf of the licensee. We were satisfied that NNB GenCo was providing effective oversight of its supplier’s manufacturing activities.
Based on the evidence sampled we concluded that:
- NNB GenCo is providing adequate oversight of the manufacturing activities carried out by its supplier;
- we gained sufficient confidence that the pumps manufactured by the 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.
- NNB GenCo is maintainingsufficient oversight of factory acceptance testing for the safety injection pumps.
- We therefore concluded that an overall inspection rating of green (no formal action) was appropriate against LC17 and LC19.