Date(s) of inspection:
- March 2023
Aim of inspection
Aim: To provide ONR with confidence that NGL’s Supply Chain and Nuclear Fuel Supply Chain (NFSS) management systems are adequately controlling and implementing the supply chain arrangements, with appropriate consideration of the current and future nuclear safety needs of the business.
Subject(s) of inspection
- LC17 – Management systems – Rating: GREEN
Key findings, inspector’s opinions and reasons for judgement made
This was a planned Licence Condition (LC) 17 – Supply Chain inspection at EDF Energy Nuclear Generation Ltd.’s (NGL’s) corporate headquarters, undertaken as part of the intervention strategy for the Operating Facilities Division (OFD) of Office for Nuclear Regulation (ONR).
The work was carried out in accordance with the planned inspection programme contained in the Corporate Integrated Intervention Strategy (IIS) for 2022/23 and as part of the 2022/23 intervention plan for operating reactors Supply Chain and Quality Assurance strategy.
The purpose of the LC17 intervention is to ensure the licensee has established and implemented Supply Chain management systems which give due priority to safety and within its management systems, make and implement adequate quality management arrangements in respect of all matters which may affect safety.
The inspection was carried out in conjunction with NGL’s Internal Nuclear Assessment (INA) and conducted on site at NGL’s headquarters at Barnwood. The inspection assessed the adequacy and implementation of the Supply Chain management system, it’s maintenance, continuous improvement, and LC compliance through process control, with specific focus on LC 6 – Records, LC7 – Incidents on site, LC 10 – Training, LC 17 – Management Systems, LC 25 Operational records and LC28 – Examination, inspection, maintenance and testing. In addition the arrangements for oversight and assurance of the Supply Chain management systems through quality audits were inspected.
The intervention was performed in line with ONR’s guidance (as described in our technical inspection guides – www.onr.org.uk/operational/tech_insp_guides/index.htm). Further information on ONR’s inspection ratings is available at – http://www.onr.org.uk/intervention-records/onr-inspection-rating-guide.pdf.
Key findings: The Supply Chain management system, the associated governance, continual improvement, together with the process management, ownership arrangements and management review arrangements were found to be adequate and suitably implemented.
However, shortfalls were found concerning a lack of clarity and the implementation of some of NGL’s arrangements and against relevant good practice (RGP). To address the shortfalls found INA raised six Condition Reports (CR’s). The shortfalls included inconsistent verification checks of supplier certification, lack of clarity of quality review responsibilities, lack of clarity of the definition of metrics, inconsistent application of the audit & assessment process, lack of proportionate use of quality in contractor forums and inconsistent implementation of arrangements for determining and managing the shelf life of items in stores which contain soft parts. INA also raised one letter of concern to address the timely appointment of a new Fleet Safeguards lead. I have raised two Regulatory Issues (RI’s) to address a lack of clarity on quality oversight arrangements, together with the Intelligent Customer arrangements and the implementation of records management arrangements.
I am satisfied the actions contained in the INA CR’s, letter of concern and the RI’s raised will address the shortfalls found.
The Supply Chain management system, the associated governance, continual improvement, together with the process management, ownership arrangements and management review arrangements were found to be adequate and suitably implemented.
The inspectors concluded from the sample conducted that the Supply Chain management arrangements were consistent with requirements described in ONR guidance. I judged the Supply Chain management arrangements adequate and rated the inspection Green (no formal action required).
However, shortfalls were found in the implementation of NGL arrangements and against relevant good practice (RGP). To address the shortfalls found INA raised one letter of concern and six Condition Reports (CR’s). I have raised two Regulatory Issues (RI’s).
INA and ONR will maintain oversight of these actions through routine meetings with NGL’s Supply Chain function.