- Site: Hinkley Point C
- IR number: 19-029
- Date: November 2019
- LC numbers: 17
Executive summary
Purpose of Intervention
The purpose of the intervention was to examine the adequacy of NNB Generation Company (HPC) Limited’s (NNB GenCo) second tier manufacturer’s capabilities, including controls and processes, to manufacture components for the polar crane. The Office for Nuclear Regulation (ONR) sought to gain confidence in the project’s oversight, as well as ensuring that the fabrication of sub-assemblies will be adequate in terms of fulfilling the safety case requirements for the polar crane.
Interventions Carried Out by ONR
ONR carried out a Licence Condition (LC) 17 (Management systems) intervention related to the manufacture of the polar crane. LC17 requires that licensees establish and implement management systems which give due priority to safety.
This intervention took place at two manufacturers of components for the Hinkley Point C polar crane on the 26th and 28th of November 2019. The manufacturers were Breman Machinery in the Netherlands and Asturfeito in Spain. APCO Technologies, the tier one supplier of the polar crane and main contract holder, was in attendance with both manufacturers.
Explanation of Judgement if Safety System Not Judged to be Adequate
Not applicable.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
The following was demonstrated during the intervention:
- Breman Machinery and Asturfeito have in place adequate controls and arrangements to ensure fabrications are compliant with safety case requirements.
- NNB GenCo has adequate oversight of Breman Machinery and Asturfeito, which are second tier manufacturers.
ONR examined NNB GenCo’s arrangements, through APCO Technologies and its two subcontractors, for the control of quality management systems, for supply chain management and for technical competence. ONR noted areas of good practice, specifically, that both manufacturers have in place good arrangements for the traceability of materials used in projects. The following minor shortfalls were identified, which will be followed up through routine ‘Nuclear Island’ engagements with NNB GenCo:
- both manufacturers showed a reliance on the veracity of their suppliers’ certifications, since they do not sample and undertake independent verification of the supplied materials;
- formal processes for the management of counterfeit, fraudulent and suspect items did not appear to be developed and in place at both manufacturers;
- conditions arising from start of manufacturing Engineering Readiness Reviews are not always reflected in manufacturers’ documentation;
- EDF Industrial Division (DI) surveillance activities were not recorded in a timely manner on Follow Up Documents (FUDs), Quality Plans; and
- there is no clear implementation of DI risk mitigations identified in the Surveillance Offer.
Conclusion of Intervention
ONR is satisfied that both Breman Machinery and Asturfeito appear to be capable fabricators of heavy engineering assemblies. Whilst a number of minor shortfalls were identified, ONR has sufficient confidence that the sub-assemblies fabricated should be adequate in terms of fulfilling the safety case requirements for the polar crane.
Based on the discussions, observations and evidence from NNB GenCo, APCO Technologies, Breman Machinery and Asturfeito, ONR judged that NNB GenCo’s implementation of its LC17 arrangements to be ‘Green’ (no formal action required) for both Breman Machinery and Asturfeito.