Executive summary
Purpose of Intervention
The purpose of this intervention was to seek assurance that NNB Generation Company (HPC) Ltd (NNB GenCo) has implemented adequate arrangements, behaviours, and culture for the management of manufacturing oversight and the associated Lifetime Quality Records (LTQRs).
Interventions Carried Out by ONR
The intervention involved a cross-cutting team of specialist inspectors from ONR and the Environment Agency (EA) and consisted of a combination of documentation reviews and interviews with key staff across six related elements, from early stages (specification), through quality arrangements for ensuring quality of items during manufacture, before delivery to site, upon receipt at site and before installation, to records management of site-based construction.
The intervention focussed on Licence Conditions (LC) 6 and 17:
- LC6 – requires a licensee to make adequate records to demonstrate compliance with any of the conditions attached to its licence.
- LC17 – requires a licensee to make and implement a management system that gives due priority to safety.
ONR assessed NNB GenCo’s LC arrangements against relevant good practice, which included ONR regulatory guidance, specifically relevant Technical Inspection Guides and Technical Assessment Guides.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
The Hinkley Point C (HPC) Guide to Quality and the Manufacturing Hub Manual describe NNB GenCo’s system, and we found evidence of that system being applied.
For the contracts reviewed, there was evidence of Revision 2 of the LTQRs specification being clearly cascaded into contracts and the contractor’s subsequent acceptance of the requirements. However, in some instances, ONR identified shortfalls in the adequacy and completeness of the End of Manufacturing Records (EoMRs) and NNB GenCo’s partitioning strategy.
ONR observed that NNB GenCo was effectively utilising Teamcenter, Contract Event Management and Reporting (CEMAR) and Consolidated Change Information System (CCIS), with evidence of accessible, real-time records.
ONR identified discrepancies between the Manufacturing Hub Manual and the Gateway Readiness Review Procedure, in relation to the requirements for undertaking gateway reviews. NNB GenCo acknowledged the discrepancies and committed to clarify the relevant documentation to determine when gateway reviews should be conducted.
From the contracts sampled, ONR observed some shortfalls relating to inconsistent standards and expectations across the Project Management and Quality functions (i.e. Programme Definition Documents, Project Definition Documents, Quality Execution Plans).
ONR noted that there was clear evidence of internal and external learning being captured, analysed, and applied to inform future activities, such as modulation of Surveillance Offers and revisions to management system arrangements. It is envisaged that the new learning tool ‘Insight’ will further promote a learning culture for HPC and provide subsequent learning for Sizewell C (SZC).
For some of the contracts sampled, shortfalls were identified in the completeness, accuracy, and quality of records, and so did not meet the minimum and required standards.
Conclusion of Intervention
NNB GenCo has delivered notable improvements in its arrangements and their implementation for the management of manufacturing oversight and the associated LTQRs. However, some specific shortfalls were found regarding their implementation that require further improvement. Therefore, an AMBER rating has been assigned to this intervention.
These shortfalls will be taken forward as follows:
- Findings relating to LTQRs will be progressed via the existing Regulatory Issue 7506.
- A Regulatory Issue will be raised to address matters relating to the adequacy and completeness of the EoMRs and NNB GenCo’s partitioning strategy.
- A Regulatory Issue will be raised to address the inconsistent standards and expectations across the Project Management and Quality functions for key documentation.
A number of less significant matters were identified during the intervention that will be progressed through future interventions and/or routine Level 4 meetings.