- Site: Non-site specific
- IR number: 20-047
- Date: January 2021
- LC numbers: N/A
Executive summary
Purpose of Intervention
The purpose of this vendor inspection was to gain confidence in Jacobs Clean Energy Limited’s (JCEL) arrangements for supply chain management (SCM) and procurement activities for nuclear safety related items or services
This intervention was part of the current ONR strategy for vendor inspections.
Interventions Carried Out by ONR
The inspection determined the adequacy of JCEL’s supply chain management arrangements and its implementation against ONR’s regulatory expectations, informed by relevant good practice and ONR guidance documentation.
This intervention relates to Licence Condition 17, which requires a Licensee to make and implement a management system that gives due priority to safety. JCEL is not a Licensee but needs to interface and align with Licensees’ systems as a supplier to them. Regulatory expectations for supply chain management arrangements and procurement activities for nuclear safety related items or services are in NS-TAST-GD-077: Procurement of Nuclear Safety Related Items or Services.
The inspection covered the adequacy of JCEL’s supply chain management arrangements and the application of those arrangements in relation to two sampled projects. The projects sampled were from projects performed at Dounreay and Dungeness A sites.
This inspection was rated based on the ONR inspection rating system guidance as explained ONR-INSP-GD – 064 - ONR ‘Compliance Inspection Guide’. This is available on the ONR external website.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
During the inspection, I found JCEL’s supply chain management arrangements to have positive attributes which included the establishment of:
- The Head of the Profession role to provide oversight of the JCEL technical resource.
- The JCEL Competency Assessment System (CAS) to provide governance of its competency assessments.
- Lifetime Quality Records (LTQR) guidance for its suppliers.
- A graded approach to its procurement activities based on nuclear safety risk.
However, I have identified a number of areas that presented increased potential risks to its supply chain management arrangements. These potential areas of increased risk are as follows:
- Based on the samples examined and discussions held, JCEL’s arrangements did not adequately demonstrate how the licensee’ s safety case requirements were captured in its supply chain management arrangement. ONR acknowledged that JCEL has developed project specific procurement strategies, however JCEL confirmed that it did not have an overarching corporate commercial/supply chain strategy that defined its supply chain management objectives for the provision of nuclear safety related items or services.
- There was a lack of adequate management system arrangements for the effective management and oversight of Counterfeit, Fraudulent and Suspect Items (CFSI).
- There was a lack of adequate management system arrangements for the management and oversight of Operational Experience (OPEX).
- Examples were identified of inadequate implementation of supply chain management arrangements. In isolation they would not be significant. However, in aggregation, they reduce confidence in the adequate implementation of JCEL’s arrangements and represent a more significant risk.
Conclusion of Intervention
I have found areas where JCEL’s supply chain arrangements were demonstrably effective. However, I have identified a number of areas where these arrangements were not adequate when compared to relevant good practice and could contribute to increased risk when procuring nuclear safety related items or services.
I have judged that an ONR inspection rating of AMBER seek improvement is appropriate.
I will monitor the JCEL’s improvement activities to address these areas of increased potential risk by raising a Level 4 (i.e. the lowest level) Regulatory Issue (RI)