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NSSS 13: LC 19 NSSS Manufacturing quality review

  • Site: Hinkley Point C
  • IR number: 20-034
  • Date: March 2021
  • LC numbers: 19

Executive summary

Purpose of Intervention

ONR is conducting a series of interventions and licensee engagements related to the quality of the nuclear steam supply system (NSSS), eventually leading to the permissioning of NNB Generation Company (HPC) Ltd’s (hereafter referred to as NNB GenCo) hold point, ‘receipt of first NSSS at site’.

Framatome is the supplier of most of the NSSS and in response to quality shortfalls observed during 2018 and 2019 at its factories at St Marcel and Le Creusot, Framatome introduced a quality improvement plan commencing at the beginning of 2020.

ONR seeks confidence that NNB GenCo is exercising adequate control over the manufacturing quality and is overseeing the implementation of quality improvements being implemented in the NSSS supply chain. The main purpose of this intervention was to review NNB GenCo’s oversight of the quality improvement plan during 2020 and for the ongoing improvements planned for 2021.

Interventions Carried Out by ONR

I conducted a Licence Condition (LC) 19 (Construction or installation of new plant) compliance inspection targeted on the nuclear steam supply system (NSSS). LC19 requires that where the licensee proposes to construct or install any new plant, which may affect safety, the licensee makes and implements adequate arrangements to control the construction or installation.

I assessed NNB GenCo’s LC arrangements against relevant good practice, which included ONR regulatory guidance.

Key Findings, Inspector's Opinions and Reasons for Judgements Made

There appears to be stable and effective daily management of quality at Framatome St Marcel and improved early involvement in deviations was seen as beneficial to their resolution.

EdF Direction Industrielle (DI) surveillance offers are in place for St Marcel and other offers are close to being issued for the major suppliers of NSSS items. DI was adopting a new approach for its surveillance, focussing on equipment related activities rather than factory based activities. Although it was expected that inspections under this new approach will be more effective, NNB GenCo will need to monitor this to ensure that the benefits are realised.

NNB GenCo have reinforced measures at ENSA to secure the quality of non-destructive testing for HPC items that have been subcontracted by Framatome.

I consider that NNB GenCo’s oversight of the quality improvements at Framatome had not been sufficiently robust to ensure the quality improvement plan had delivered and continues to deliver improvements that align with the demands of the HPC NSSS programme. My reasons for this judgement are:

  • NNB GenCo’s regular and frequent engagements with Framatome to assess the progress of the Framatome quality improvement plan have lapsed, with the last formal engagement under NNB GenCo’s oversight arrangements being in November 2020.
  • The overall key performance indicators for the quality improvement plan had not been met. NNB GenCo was unable to explain whether the improvements made through 2020 were sufficient to meet the demands of the HPC NSSS programme.
  • Framatome was continuing its quality improvement plan through 2021 and NNB GenCo believes that priority may have been given to the EdF Excell quality improvement initiative in shaping the ongoing actions. NNB GenCo had not reviewed the 2021 plan and actions to judge whether it was likely to meet the demands of the HPC NSSS programme.

Conclusion of Intervention

Overall, I have concluded that an inspection rating of AMBER is appropriate for LC19 (Construction or installation of new plant).

I have not raised any new regulatory issues as a result of the above findings. The findings will be used to inform the progress of the existing level 3 regulatory issues 8035, ‘NNB GenCo surveillance arrangements for the HPC primary circuit components manufactured at Framatome Saint Marcel & Creusot Forge’ and 8037, ‘NNB GenCo quality management arrangements for the HPC primary circuit components manufactured at Framatome Saint Marcel & Creusot Forge’.