- Inspection date(s): 27/09/2022
Purpose of inspection
The purpose of this intervention was to check the operation of NNB Generation Company (HPC) Limited’s (NNB GenCo) Hinkley Point C’s (HPC) manufacturing hub which is part of NNB GenCo’s quality and supply chain management arrangements. The hub approach enables coordination of various oversight activities required by NNB GenCo for equipment supplied to it. They are co-ordinated through a pre-requisite model, where certain requirements (“pre-requisites”) must be in place at certain points (“milestones”) from the start of manufacture through to delivery to site. Manufacturing oversight activities underpin nuclear safety and are generally performed at suppliers’ premises by Direction Industrielle (DI), a part of EDF SA, as a contractor to NNB GenCo.
The intervention is part of the current Office for Nuclear Regulation (ONR) strategy for regulating HPC and follows earlier inspections at the hub in 2019 and 2020.
Subject(s) of inspection
The following actives were the subject of this inspection:
- LC17 – Management systems – Rating – Green
The intervention was carried out over 2 days at the hub’s location within DI’s offices in Paris. A further day was spent at NNB GenCo’s offices in the UK.
Each day was structured around an agenda allowing discussions with key personnel and live examination of relevant documentation within NNB GenCo’s computer systems.
The inspection team sampled records relating to contracts in flight whose manufacturing surveillance has been coordinated via staff located at the hub.
The inspection team talked directly with DI personnel at the hub.
Overall, the inspection team was satisfied that the hub and pre-requisite model were in place and operating as part of NNB GenCo’s system for manufacturing surveillance of equipment being supplied to them.
ONR concluded, from the evidence, that:
- There was adherence to the Manufacturing Hub Manual and the pre-requisite model espoused in the manual to control and co-ordinate manufacturing by suppliers.
- There was control and co-ordination of supply chain activities, includingconcessions / non-conformance report (NCR) management and product release.
- There was manufacturing surveillance performed by DI and its effectiveness had been improved since earlier interventions at the hub, and further improvements were in progress. The surveillance performed by other inspection bodies, such as Bureau Veritas, was not explored.
- Senior managers in NNB GenCo need to consider the future strategic direction of the hub and how it fits into wider governance of effective manufacturing surveillance by HPC.
- The ONR team highlighted areas for NNB GenCo and DI to address, but rated the intervention green as it is expected that NNB GenCo and DI will take forward the areas for improvement without formal regulatory action by ONR.