Date(s) of inspection:
- October 2022
Aim of inspection
The aim of the inspection was to assess application of NNB Generation Company (HPC) Ltd's (NNB GenCo) Licence Condition (LC) 17 and LC19 arrangements for controlling the release of the Hinkley Point C (HPC) unit 1 reactor pressure vessel (RPV) by focusing on the end of manufacture records (EoMRs) produced by Framatome. The main objective was to review the production of the EoMRs including an examination of the process for producing the EoMR. The inspection also reviewed Framatome St Marcel's progress in addressing the findings of level 3 regulatory issue RI-10959 'Framatome High Integrity Component (HIC) manufacturing records'.
Subject(s) of inspection
- LC17 - Management systems - Rating - Green
- LC19 - Construction or installation of new plant - Rating - Green
Key findings, inspector's opinions and reasons for judgement made
Based on a sample review of the records for the RPV, it was established that they were complete.
Discussions with the independent third party inspection agency (ITPIA) and EDF SA Direction Industrielle (DI) surveillance teams supported the judgement that the surveillance had been performed in accordance with the relevant plans.
A previous inspection at Framatome had identified shortfalls in the administration and maintenance of manufacturing records at St Marcel and a regulatory issue was raised against NNB GenCo to ensure that appropriate improvements were made. The inspection reported here examined the status of the improvements and established that satisfactory progress was being made. It is therefore expected that there will be no barriers to resolving the issue in the planned timescales.
From the evidence gathered, I was satisfied that NNB GenCo, the licensee, is exercising an appropriate level of control in line with its LC17 and LC19 arrangements in the generation of the EoMR for the unit 1 RPV and that the EoMR, along with the certificates provided by the surveillance bodies, are sufficient for NNB GenCo to release the unit 1 RPV to the status of ex-works prior to shipment.
The inspection concluded that a guidance document was needed to aid users of the EoMR in relating an assembly to its constituent parts and that clarity is required in how NNB GenCo will have continued access to internal inspection records generated by Framatome.
Conclusion
I have reviewed the process for generating the EoMR for the HPC unit 1 RPV and concluded that, in general, the records were appropriately managed and controlled. Whilst there were some outstanding activities associated with the shipment of the RPV I was satisfied that the principal surveillance bodies, ITPIA and DI, will have achieved the level of surveillance identified in their respective plans prior to ex-works. From my sample review of the EoMR I concluded that it was, on the whole, comprehensive and suitable for NNB GenCo's lifetime quality records. I identified some areas for improvement that can be followed up through routine regulatory business.
I gathered evidence that enabled me to conclude that Framatome had made adequate progress in improving the administration of records and in producing digital back-ups.
Overall, I judged that NNB GenCo was exercising adequate control according to its LC17 and LC19 arrangements over the production of the EoMR and that NNB GenCo will be able to make a confident decision regarding the release of the RPV for shipment. I therefore rated this inspection as green (no formal action).