ONR Chief Nuclear Inspector Report of EDF Energy and Hinkley Point C Supply Chain

Title of document
INTERVENTION RECORD
Unique Document ID ONR-NR-IR-17-014
TRIM Ref: 2018/0007288
and Revision No: Revision 0 Version 1
Hinkley Point C (HPC) - Chief Nuclear Inspector’s Inspection of EDF
Location and purpose
NNB GenCo (HPC) Ltd’s Supply Chain Management Arrangements
of Intervention:
Principal Inspector & Supply Chain and Quality
Professional Lead (Inspection Lead)
Superintending Inspector & Head of AP1000
Construction
Specialist Nuclear Inspector, Structural Integrity
Specialist Nuclear Inspector, Structural Integrity
Superintending Inspector & Head of EPR
Construction
Chief Nuclear Inspector (DCC Opening Meeting
Only)
Deputy Chief Nuclear Inspector & Director of
ONR Inspector(s)
New Reactor Construction (DCC Opening
taking part in
Meeting Only)
Intervention:
Principal Inspector & HPC Site Inspector
Principal Inspector & HPC Organisational
Capability Cornerstone Lead
Specialist Nuclear Inspector, Supply Chain &
Quality
Specialist Nuclear Inspector, Supply Chain &
Quality
Superintending Inspector & Regulatory
Oversight Manager
Principal Inspector & Head of Regulatory
Intelligence
10th & 11th Oct. 2017 Areva’s Creusot Forge, Le Creusot,
France
27th to 29th Nov. 2017 Delivery Command Centre, Bristol
Date(s) of Intervention: 30th Nov 2017 Engineering Command Centre, Paris,
France
30th Nov. & 1st Dec. 2017 Site Command Centre, Hinkley Point C
Construction Site
PRINCIPAL STAFF SEEN
The roles of principal staff seen, including those from licensees or other government departments (for
example, the Environment Agency) seen during the visit
Record
Organisation Role Name
Section
See Appendix 1
(B) INTERVENTION RATINGS
Record LC / Series P/
Intervention Details Plan Name Rating
Section Code RUP*
Page 1 of 30
Record ONR-NR-IR-17-014
TRIM Ref 2018/0007288
2.1 LC 17 Planned Inspection NNB GenCo (HPC) 17 Amber P
Office for Nuclear Regulation Page 2 of 30

TRIM Ref 2018/0007288
TABLE OF CONTENTS
1 EXECUTIVE SUMMARY ..................................................................................................... 4

2 INSPECTION RECORD .................................................................................................... 10
3 CONCLUSIONS ................................................................................................................ 21
4 ISSUES.............................................................................................................................. 25

TRIM Ref 2018/0007288
1 EXECUTIVE SUMMARY
1.1 Purpose of intervention - Inspection aims & approach
1. This Chief Nuclear Inspector’s (CNI) Inspection was established following shortfalls
identified at Areva’s Creusot Forge (ACF) facility, one of NNB GenCo (HPC) Ltd’s
(NNB GenCo) key suppliers. The shortfalls challenged the adequacy of NNB GenCo’s
supply chain management arrangements, including the effectiveness of their supply
chain oversight and assurance arrangements.
2. ONR had previously participated in a multinational inspection of ACF during

November/December 2016, led by the French Nuclear safety Regulator, Autorité de
Sûreté Nucléaire (ASN) as part of the Multinational Design Evaluation Programme
(MDEP). The MDEP, Vendor Inspection Cooperation Working Group (VICWG) had
targeted the ACF facility due to regulatory concerns regarding historic product record
irregularities. The MDEP inspection identified shortfalls in Areva’s quality management
arrangements and the adequacy of their corrective action plan.
3. As a result of the shortfalls, a targeted Level 1 meeting was held with NNB GenCo in
February 2017, and was considered an initial step in rebuilding confidence in NNB
GenCo’s Intelligent Customer arrangements. NNB GenCo subsequently wrote to the
CNI detailing their improvement action plan and associated governance arrangements
(TRIM 2017/85011).
4. ONR committed to a future Level 1 meeting prior to the end of the 2017/18 financial
year and the CNI identified that a supply chain focussed CNI’s inspection would be
deployed to inform the engagement.
5. The purpose of this supply chain focussed CNI’s inspection was to assess the
adequacy of NNB GenCo’s supply chain management arrangements including
oversight and assurance and improvement action plan, specifically focussed on:
 the effective deployment of lessons for other key contractors and the
enhancement to NNB GenCo’s supply chain oversight and assurance
arrangements
 the effective deployment of Areva’s improvement programme, specific to ACF
and associated manufacturing facilities
 the adequacy of Areva’s enhanced manufacturing processes - informed by the
Nuclear Steam Supply System (NSSS) workstream and supported by ONR’s
Structural Integrity team
 improvements to ACF’s nuclear safety and quality culture
 effective deployment of NNB GenCo’s associated organisational changes
6. This targeted CNI Inspection, in the early stages of NNB GenCo’s construction and
manufacturing programmes, gave ONR the opportunity to assess the project’s supply
chain management arrangements and reinforce its regulatory expectations. The timing
allows NNB GenCo to respond as required to any identified shortfalls prior to the
acceleration of HPC construction and manufacturing activity.
7. The CNI’s Inspection scope was defined on an approved project task sheet (TRIM
2017/313658).
1.2 Purpose of CNI sponsored inspections
8. As described in ONR Guide ONR-INSP-GD-059 Rev. 5, CNI inspections differ from

more routine ONR inspections in that they are specifically identified and commissioned
by the CNI. The purpose of the inspection is to inform the CNI’s position on a specific
regulatory matter that is of a strategic nature, for example, having high current or

TRIM Ref 2018/0007288
potential safety or security significance, or having the potential to adversely impact

public confidence.
9. A CNI Inspection will usually involve engagement at a senior level and may involve
multiple sites and duty holders, as well as other stakeholders with an interest in the
matter being inspected. It may, as in this inspection, include visits and engagements
internationally.
1.3 Interventions carried out by ONR
10. This CNI’s inspection had four interconnected elements, commencing at ACF and
progressing to the HPC site to assess the effective deployment of lessons for NNB
GenCo’s other key contractors. The four elements of the inspection were conducted on
the following dates:
 Element 1 - Areva’s Creusot Forge, France - 10th & 11th October 2017
 Element 2 - Delivery Command Centre, Bristol - 27th to 29th November 2017
 Element 3 - Site Command Centre, HPC Construction Site - 30th November &
1st December 2017
 Element 4 - Engineering Command Centre, Paris, France - 30th November
2017
11. The outcome of each inspection was recorded in individual Contact Records enabling
the full conclusions and judgements of the CNI inspection to be recorded on this
overarching Intervention Record.
1.4 Key findings, inspector's opinions and reasons for judgements made
12. Throughout this CNI’s inspection, themes have emerged that relate to both
improvements in NNB GenCo’s processes and to shortfalls in management system
arrangements that, if unresolved, have the potential to affect safety.
13. Initial conclusions and judgements were formed by the ONR inspection teams after
each inspection element. Any preliminary findings identified during these inspection
elements were subsequently considered collectively on completion of the whole
inspection scope, and where regulatory shortfalls were identified, Regulatory Issues
have been raised.
14. I have analysed the key findings and judgements of this CNI’s inspection and consider
that they can be most appropriately defined against the six themes identified in the
sections below.
15. Section 1.4.1 reflects positive progress made by NNB GenCo and its key supplier
Areva and therefore no associated Regulatory Issue has been raised. However, I will
raise an associated Regulatory Issue as appropriate for each of the themes in sections
1.4.2 to 1.4.6, to define the required improvement activity.
16. The scope of the CNI inspection was specifically targeted at supply chain management
and associated areas. NNB GenCo is currently undertaking work associated with
design, construction and early manufacturing activities. Although arrangements for
control of quality are judged, through ONR’s wider regulatory activities, to be
appropriate at present, this inspection has identified a number of areas where
improvements are required to ensure this position is robustly maintained as the project
progresses and the volume of work and resources required increases.

TRIM Ref 2018/0007288
1.4.1 Areva’s improvement programme
17. The CNI’s inspection placed emphasis on the adequacy of enhanced arrangements at
ACF. The inspection team concluded that ACF and NNB GenCo had made good
progress in deploying their improvement programme and had enhanced their
manufacturing processes, management system arrangements and the facilities’
nuclear safety and quality culture.
18. Overall, I am broadly satisfied with the enhanced management system arrangements. I
note however, as the improvement programme is not yet fully deployed, ACF’s
enhanced arrangements have yet to be fully embedded and therefore will require
continued drive and appropriate oversight and assurance from NNB GenCo as the
Intelligent Customer for the products supplied by ACF, in order to be demonstrated as
sustainable over the longer term.
19. The enhanced arrangements included evidence of strengthened assurance activity

within NNB GenCo’s Manufacturing, Inspection and Testing (MIT) function, and EDF
Group’s CEIDRE (Centre d’Expertise et d’Inspection dans les Domaines de la
Realisation et de l’Exploitation) manufacturing inspection department, that will be
essential as the equipment manufacturing programme accelerates as the project
progresses.
20. I recommend that ONR continue to assess NNB GenCo’s and Areva’s progress
through the existing ‘Areva Manufacturing’ regulatory workstream.
1.4.2 Learning associated with shortfalls at ACF
21. Evidence was not provided during the inspection to demonstrate how NNB GenCo had
captured all the key learning from the issues associated with the failings at ACF, and
ensured its effective promulgation to NNB GenCo’s key contractors interviewed as part
of this inspection. I did however recognise that evidence was available of the learning
for site contractors from the similar issues associated with First Nuclear Safety
Concrete (FNSC) substitution concrete pour.
22. The CNI Inspection scope emphasised that it would consider the effective deployment
of lessons for other key contractors. Therefore, I consider it important that NNB GenCo
evaluate how it has captured the key learning from the shortfalls at ACF and consider if
it has been effectively promulgated within its organisation and its key contractors.
1.4.3 Supply chain self-assessment improvement programme
23. I consider that NNB GenCo’s improvement plan, derived from of its supply chain self-
assessment, requires further development as the version provided to the ONR
inspection team was not effectively prioritised, time bound, resourced and aligned to
the HPC construction schedule and agreed regulatory permissioning points. I am of the
view that this version is not adequate given that improvement activities relate to
shortfalls in management system arrangements which, if unresolved, have the
potential to affect safety.
24. Furthermore, I consider that the improvement plan should be subject to appropriate
project wide governance and leadership to ensure that it is prioritised on project risks,
noting that the existing plan places emphasis on the development of the improvement
activities on an individual directorate basis.
1.4.4 Quality Management System shortfalls
25. This inspection has found shortfalls in NNB GenCo’s quality management system
arrangements related to supply chain management activity. Some shortfalls were

TRIM Ref 2018/0007288
identified during NNB GenCo’s supply chain self-assessment activity performed in

advance of this inspection. However, this CNI’s inspection identified the following
management system shortfalls that will require resolution:
 Inspection & Test Plans (ITPs) - NNB GenCo has identified that it needs to
improve its guidance with regards to the preparation and use of ITPs and that
they should be consistently implemented. I consider that this will be beneficial
in reducing construction quality risks and should ensure that some of the
inconsistencies in implementation identified during this inspection are
addressed or subject to a formal NNB GenCo assessment or approval
processes.
 Internal Assurance Programme – The supply chain self-assessment did not
identify shortfalls in NNB GenCo’s internal assurance programme, which the
CNI’s inspection team subsequently identified. The assurance function had not
completed any internal process audits during 2017, with no future audit
programme available. The lack of an internal process assurance programme
was disappointing as an effective programme may have prevented many of the
shortfalls identified both in the supply chain self-assessment and in this
inspection.
 Supply Chain Assurance - The CNI inspection team identified potential risks
with NNB GenCo’s oversight and assurance arrangements for work sub-
contracted by their Tier 1 suppliers at both ACF and with site contractors. I
have challenged NNB GenCo to ensure that their approach is commensurate
with risk, regardless of where it arises in the supply chain, rather than being
focussed on Tier 1 suppliers.
26. I consider that further development of NNB GenCo’s management system

arrangements is important to reduce reliance on the competence of individuals to
compensate for lack of procedural clarity. This shortfall was highlighted on the
construction site related to the ITPs and gaps in project quality documentation.
Addressing this should ensure that quality management system arrangements are
consistently implemented across the project as it accelerates and the work and
number of contractors on site increases.
1.4.5 Roles & responsibilities for quality
27. The CNI inspection team found a lack of clarity over the project wide leadership of
NNB GenCo’s quality organisation and who had the responsibility for establishing an
effective management system and communicating the quality standards, roles and
responsibilities across the project to ensure ‘right first time’ delivery on the construction
site.
28. I noted during the inspection that NNB GenCo were in the process of reviewing their
quality organisational arrangements as part of a wider Management of Organisational
Change submission. I consider it important that this change clarifies the roles and
responsibilities for quality delivery on the project and enhances the coordination
between the site and supporting quality functions.
1.4.6 Internal assurance activities
29. This CNI inspection has identified shortfalls in supply chain management system
arrangements important to safety and roles and responsibilities important to safety.
30. The supply chain self-assessment completed by NNB GenCo prior to this CNI
inspection identified a number of additional shortfalls that require resolution.

TRIM Ref 2018/0007288
31. Given the conclusions of the CNI inspection, I consider that NNB GenCo should further
review its current project assurance arrangements and consider appropriate areas for
improvement.
1.5 Inspector’s rating
32. The individual findings from the various elements of this CNI Inspection highlight a
number of deficiencies in NNB GenCo’s management system arrangements. These
individual deficiencies, taken on their own, may not be of such seriousness to raise a
regulatory issue; however in aggregation they indicate a broader deficiency in NNB
GenCo’s arrangements and I judge that overall five Regulatory Issues, aligned with the
thematic shortfalls identified above, should be raised.
33. I have concluded that these Issues represent shortfalls against LC 17 – Management
Systems.
34. Through its wider regulatory interventions, ONR consider that current arrangements,
coupled with the competence of personnel, are capable of managing current
workscope. However, they may not be sufficient as the project moves forward and
work volumes and required resources increase. There is a need, therefore for NNB
GenCo to develop these arrangements further to provide sustainable control as the
work expands.
35. The Regulatory Issues identified represent a failure to implement or meet compliance
arrangements and therefore I am allocating an Inspection rating of Amber – Below
Standard.
1.6 Conclusion of intervention
36. This CNI’s inspection has achieved its purpose and was efficiently and effectively
delivered to plan as defined in the approved project task sheet (TRIM 2017/313658).
37. The differing elements of the inspection involved a total of eleven ONR inspectors with
two ASN inspectors observing while at ACF. The significant number of NNB GenCo
and its supply chain staff engaged with as part of this inspection demonstrates the
scale, strategic nature and safety significance of the inspection scope.
38. NNB GenCo has successfully facilitated this inspection with the support of its supply
chain ensuring that each element of the inspection achieved its purpose. This involved
considerable coordination with ONR in advance of, and during the inspection. I
anticipate that this positive support will continue as the issues raised in this inspection
are resolved.
39. The CNI inspection was performed in the early stages of NNB GenCo’s construction
and manufacturing programmes. The timing will allow NNB GenCo to address the
identified shortfalls prior to the acceleration of HPC construction and manufacturing
activity.
40. The inspection has identified five thematic shortfalls which will each be tracked to
closure through an associated Regulatory Issue. The resolution of these issues will
help mitigate the risk of substandard manufacture and construction quality and
potential impacts to the construction schedule and ONR’s project permissioning
decisions. They may also make a positive contribution to the safe and reliable
operation of the HPC Nuclear Power Plant during its operational phase.
41. I consider that the with the correct application, NNB GenCo will be able to implement
the required improvements and close the five Regulatory Issues in advance of

TRIM Ref 2018/0007288
regulatory assessments associated with the Nuclear Island Concrete permissioning

point currently scheduled for August 2018.
42. Timely resolution of the identified issues will reduce project risk and contribute to NNB
GenCo’s aim of quality, ‘right first time’ delivery.

TRIM Ref 2018/0007288
2 Inspection Record
2.1 CNI Inspection, Element 1 - Inspection of EDF NNB GenCo (HPC) and Areva
Creusot Forge, France - 10th & 11th October 2017
2.1.1 Inspection element objectives
43. Areva are the primary contractor for the supply of HPC Nuclear Steam Supply System
(NSSS) primary circuit items. A substantial number of the forged items that go to form
the NSSS components are produced at ACF.
44. This first element of the CNI’s inspection examined:
 The effective deployment of Areva’s improvement programme, specific to ACF

and associated manufacturing facilities;
 The adequacy of ACF’s enhanced manufacturing processes;
 Improvements to ACF’s nuclear safety and quality culture;
 Effective deployment of NNB GenCo’s associated organisational changes;
 Alignment of regulatory approaches and cooperation with the French Nuclear
Regulator Autorité de Sûreté Nucléaire (ASN).
45. The inspection was recorded on Contact Record, ONR-NR-CR-17-452 (TRIM

2017/397380) and was conducted by five ONR inspectors supported by two inspectors
from ASN.
2.1.2 Summary of inspection activity
46. To achieve the inspection scope in the most efficient manner the team separated into
two sub-teams as follows:
 Team 1 – Examined organisational changes; management system and nuclear

safety culture enhancements, NNB GenCo’s Intelligent Customer role and the
effectiveness of 3rd and 2nd party assurance activities.
 Team 2 – Examined the definition, specification and control of forging
parameters, enhancements to the Non-Conformance and deviation control
processes and the effectiveness of machining and testing operations.
47. The agenda for the visit (TRIM 2017/399010) included a presentation summarising
Areva’s improvement programme progress (TRIM 2017/399019).
48. The French nuclear regulator, ASN, participated in the inspection throughout at ONR’s
invitation to support alignment of regulatory judgements associated with the adequacy
of Areva’s improvement programme.
2.1.2.1 Organisational changes
49. This element of the inspection examined the organisational changes at NNB GenCo to
ensure enhanced supply chain management of Areva. This included the role of the
Quality Steering Group chaired by the Project Director in enhancing supply chain
management activities. It was detailed that the NSSS programme would have an
enhanced surveillance programme utilising quality resource.
50. ACF detailed the creation of new organisational posts and their progress in the
recruitment and integration of staff to ensure the establishment and maintenance of the
required nuclear safety culture.
51. The ONR team was satisfied that ACF were able to demonstrate enhanced
organisation structure and capability. They had made provision to maintain the

TRIM Ref 2018/0007288
capability at the required level. NNB GenCo had strengthened their oversight and
assurance capability at ACF, as the Intelligent Customer, and I consider the
enhancements to be an appropriate response to the identified shortfalls.
52. ONR will continue to monitor the effectiveness of these enhancements through routine
regulatory engagements with NNB GenCo, including the ongoing effectiveness of the
Quality Steering Group.
2.1.2.2 Management system, nuclear safety culture & Intelligent Customer role
53. ACF provided evidence of its enhanced management system arrangements deployed
in 2017 including their oversight by additional quality resource. This included a sample
of records associated with main coolant line forging test pieces.
54. ONR noted that NNB GenCo’s oversight focus was on their Tier 1 suppliers and as
such they had not adequately considered the risks associated with the sub-contracting
of high risk components by Areva.
55. The ONR team examined the evidence of improved nuclear safety culture by
considering the status of improvement actions in the ACF improvement plan ‘war room’
and by engaging with quality department and production staff. Evidence was available
of an improving nuclear safety culture and the ONR engagements with the ACF staff
provided an insight into the progress made, as well as highlighting further work
required to sustain the improvements over the longer term
56. NNB GenCo identified how they had established a ‘hold point’ process to agree re-start
of manufacture at ACF as the Intelligent Customer. NNB GenCo were not in a position
to demonstrate the adequacy of potential Areva sub-contractors and they had yet to
develop ‘supply chain maps’ to identify higher risk activity in lower tier suppliers, and
thus target their assurance efforts.
2.1.2.3 Third & second party inspection organisations
57. ONR considered the roles of the Lloyds Apave (Independent Third Party Inspection
Agency), EDF CEIDRE (EDF’s second party inspection agency) and AREVA EIRA
(Equipe d’AREVA, Areva’s second party inspection agency). All organisations
emphasised that they had now deployed improvements to address the shortfalls which
their previous inspection activity had failed to identify.
2.1.2.4 Development of forging processes
58. ACF demonstrated their Technical Manufacturing Programme (TMP) based on a

technical specification provided by NNB GenCo. The ONR team was satisfied with the
evidence presented to demonstrate that NNB GenCo were undertaking adequate
oversight of the arrangements, and that there was an enhanced relationship and
communication between ACF and NNB GenCo as Intelligent Customer.
59. ACF had recruited additional expert staff to support development of their forging
processes and were in the process of developing organisation wide arrangements to
make sure that critical resources were sufficient, with appropriate skills, before
restarting operations.
60. The ONR team noted again that NNB GenCo did not undertake any assessment of
contractors below Tier 1, and the responsibility lay with the main contractor to ensure
that any subcontractors were fully competent. ONR indicated that this represented a
risk and suggested that NNB GenCo should undertake its own evaluation of sub-Tier 1
suppliers on a risk basis. ONR noted Areva’s revised forging strategy, in which some

TRIM Ref 2018/0007288
forging production initially planned for ACF was contracted to other suppliers,
introducing additional uncertainty.
61. ONR noted that ACF were making good progress in establishing a competency based
resource process that was consistent with being a major nuclear supplier. While NNB
GenCo have demonstrated some oversight of ACF’s competency process, ONR
consider it important that this approach is extended to the wider supply chain using a
risk based approach.
2.1.2.5 Machining & testing operations
62. ONR visited ACFs machining facility to view HPC product, witness test activity, review
operational records and engage with associated staff. The visit demonstrated that ACF
were enhancing their production sequencing and equipment to meet HPC project
requirements.
63. The visit to the machining facility enabled ONR to make positive judgements regarding
ACF’s work control process and associated surveillance activities. ONR welcomed the
investment activities that ACF were undertaking to improve the production and control
of forgings.
2.1.2.6 Enhancements to the non-conformance & deviation control processes
64. ONR examined the process for managing quality events noting that any member of
ACF could initiate a quality event. Quality events are reviewed on a daily basis by the
quality team who categorise each event as either a discrepancy/alert, an internal Non-
Conformance Report (NCR) or a contractual NCR. The activity giving rise to the quality
event could only be resumed once rectifying operations have been identified and
enacted.
65. ONR viewed the process applied in practice for a particular quality event raised in the
machine-shop and was satisfied that the necessary steps had been followed and the
event closed out. It was noted that ACF now send discrepancy notes, which record the
event and its close out, to NNB GenCo as a matter of course. This was an indication of
the improved relationship and communications between ACF and NNB GenCo.
2.1.3 Key findings & judgements
66. Based on the evidence gathered from this element of the CNI Inspection, it is apparent
that:
 ACF have made good progress in deploying their improvement programme and
were able to demonstrate an enhanced organisation structure, capability,
culture and processes, including strengthened non-conformance control;
 ACF have plans to transition the ‘step change’ improvement programme into
normal business and to maintain the enhanced capability and culture at the
required level;
 NNB GenCo have enhanced their communication and engagements with ACF
in line with their Intelligent Customer role and have strengthened their oversight
and assurance activities as part of the overall assurance arrangements for
Areva’s NSSS item delivery.
67. I consider that ACF have developed a good process for reporting and rectifying faults
and non-conformances, and the lessons learnt through this process should lead to
overall improvements in quality. While the reporting of faults and corrective action
seemed effective it was less clear to what extent such faults could have been
prevented in the first place. Consequently, I consider it important that ACF pay due
attention to applying error prevention tools prior to commencing activities.

TRIM Ref 2018/0007288
68. This element of the CNI inspection identified potential risks with NNB GenCo’s
oversight and assurance arrangements for work sub-contracted by their Tier 1
suppliers. I have challenged NNB GenCo to ensure that their approach is
commensurate with risk arising from the product supplied, rather than being focussed
on the activities of their Tier 1 suppliers. This issue was examined further as a cross
cutting theme during the other elements of this inspection.
69. No formal issues were raised specific to this element of the CNI’s inspection; however
the findings contribute to generic issues raised on completion of all elements of the
inspection.
70. I consider that ACF and NNB GenCo have made good progress in deploying their
improvement programme and have enhanced their management system
arrangements. I am broadly satisfied with the enhanced management system
arrangements. I note however, as the improvement programme is not yet fully
deployed, ACF’s enhanced arrangements have yet to be fully embedded and therefore
can’t be considered sustainable over the longer term without continued drive and
vigilance and appropriate oversight and assurance from NNB GenCo as the Intelligent
Customer.
2.2 CNI Inspection, Element 2 - Inspection of Delivery Command Centre, Bristol -

27th to 29th November 2017
71. This second element of the CNI’s inspection examined:
 how NNB GenCo had shared the lessons learnt from the issues surrounding
the supply of high integrity items from ACF with their other key contractors;
 changes implemented in key contractor arrangements to mitigate the identified
risks;
 how NNB GenCo have strengthened their oversight and assurance
arrangements, their Intelligent Customer role and how this capability will be
maintained.
72. The agenda for this element of the CNI’s inspection was agreed in advance (TRIM
2017/447302). The inspection was conducted by six ONR inspectors and recorded on
Contact Record, ONR-NR-CR-17-570 (TRIM 2018/011307).
2.2.2.1 Opening meeting
73. The opening meeting of the inspection at the Delivery Command Centre (DCC) was
attended by both the NNB GenCo Managing Director, Stuart Crooks (SC) and the
ONR CNI, Mark Foy (MF).
74. SC acknowledged that the shortfalls at ACF should have been identified by NNB
GenCo, not ONR. He emphasised that given the positive improvement progress at
ACF, a key remaining challenge was to implement the associated learning in NNB
GenCo’s other key contractors. As the recently appointed Managing Director, SC
emphasised that he had taken the opportunity to conduct a self-assessment of NNB
GenCo’s supply chain management arrangements to determine their adequacy and
target improvements required to ensure ‘right first time’ delivery.
75. ONR’s CNI, MF highlighted the context for the ONR’s inspection and reinforced that
the purpose of this inspection was to assess the adequacy of NNB GenCo’s supply
chain management arrangements and to consider the effective deployment of ACF

TRIM Ref 2018/0007288
lessons for other key contractors. MF identified that the inspection team would
consider the progress made by NNB GenCo against commitments made by their
previous Managing Director to ONR’s CNI in February 2017, following the issues
arising at ACF (TRIM 2017/85011).
76. As CNI Inspection Lead, I confirmed the inspection objectives, summarised the
approach and reporting process as agreed with NNB GenCo in advance of the
inspection.
2.2.2.2 NNB GenCo’s supply chain process self-assessment
77. NNB identified that the objective of their supply chain self-assessment was to consider
the adequacy of their supply chain management arrangements, the responses to the
shortfalls identified at ACF and with the pouring of First Nuclear Safety Concrete (
TRIM 2017/163461) at the construction site, and to recommend improvement actions
to resolve any issues identified.
78. The self-assessment process was structured around the five phases of the supply
chain process: design and specification; pre-contract supplier capability assessment;
post signature of contract – readiness for commencement to work; manufacture and
construction; and post-manufacture to installation.
79. NNB GenCo delivered a presentation identifying that the self-assessment found
examples of good practices and improvement themes related to: documentation; the
use of resources; and the coordination and clarity of activities (TRIM 2017/447242).
80. Given the shortfalls identified by NNB GenCo, ONR amended the inspection schedule
to enable a more detailed examination of the self-assessment findings and associated
improvement programme.
81. NNB GenCo provided a copy of the draft supply chain self-assessment plan (TRIM
2018/007278), and explained that the improvement plan was produced approximately
one month previous and they planned to endorse it by the end of the inspection week.
Responsibility for delivery would fall to individual delivery directors who had been
challenged to develop resourced improvement plans.
82. ONR found that the draft self-assessment improvement identified a balance of good
practices and improvement gaps, each with the associated project risk, recommended
improvement, owner and timescale for completion. The completion timescales were
identified per quarter and the majority targeted Quarter 1, 2018. NNB GenCo
highlighted that they were enhancing their capability to meet the forward need.
83. ONR noted that the improvement plan items were not aligned to the project schedule
and forward hold points, and as such it was not clear if the improvement work was
adequately prioritised against risk. This was highlighted as important given that many
elements of the improvement gaps related to resource challenges and it would prove
challenging for the project to enhance its resource in all areas in parallel without
effective prioritisation. ONR highlighted that the additional burden on staff who already
had existing commitments should be considered as part of the prioritisation and
resourcing of the improvement plan.
84. ONR noted that the draft plan placed emphasis on the development of the
improvement activities on an individual directorate basis. ONR emphasised that they
would expect the self-assessment Improvement plan to be subject to appropriate
project wide governance and leadership to ensure it adequately targeted prioritised
project risks.

TRIM Ref 2018/0007288
2.2.2.3 NNB lessons learnt from ACF
85. NNB GenCo described their response to the shortfalls at ACF, noting that their
arrangements had not been sufficient to detect Counterfeit Fraudulent & Suspect Items
(CFSI). It was detailed that NNB had a lack of surveillance penetration on ACF,
insufficient oversight of the supply chain and insufficient oversight of independent
assessment.
86. NNB GenCo described the enhanced controls established and overseen as a result of
the formation of dedicated ACF Quality Steering Group.
87. ONR noted that they had seen evidence of the deployed improvements during the ACF
element of the CNI inspection
2.2.2.4 Project quality standards & development of supply chain quality
88. NNB GenCo provided a summary of the project’s key quality management system
arrangements, key quality roles and how they would be developed as the project
progresses (TRIM 2017/447284). NNB GenCo identified that the quality organisation
would be subject to future change as a result of a Management of Organisational
Change submission that was currently being drafted with an aim of clarifying
organisational alignment and targeting more efficient working.
89. ONR queried whether the DCC Quality Forum had been utilised to share the lessons
learnt from the shortfalls at ACF. NNB GenCo detailed that the forum had not been
used to share the learning points amongst other key project contractors and while it
may not have been the best forum to discuss the issues, a more appropriate forum
could not be identified.
90. Following the presentation of NNB GenCo’s management system arrangement ONR
requested a copy of NNB GenCo’s internal process audit programme for 2017/18 but
were informed that due to resource shortfalls, no audits had been completed
throughout 2017. Evidence was available to demonstrate that the last process audit
had been performed in 2016.
91. ONR examined the improvements identified in the First Nuclear Safety Concrete
(FNSC) Improvement Action Plan and reiterated the importance of their closure in
supporting ONR’s judgements for future permissioning points. ONR clarified their
current understanding of hold point management and quality planning.
92. NNB GenCo identified that they had issued guidance on Inspection and Test Plans
(ITP), but emphasised its use by contractors was not mandated. New guidance was
being developed by NNB GenCo to provide greater clarity for contractors. It was not
clear to ONR how the work on site was being controlled sequentially and ONR noted it
would examine the adequacy of the guidance during the site element of the inspection.
93. ONR highlighted that the role and responsibilities of the quality organisation were not
clear with regards to establishing effective management systems for the project,
setting quality standards, measuring performance and for ensuring ‘right first time’
delivery on the construction site. The lack of an audit programme examining process
arrangements was identified as an area of concern given the current stage of the
project and while ONR recognised that improvement measures were underway,
including a proposed new organisational structure, the implication of the shortfalls and
the effectiveness of the quality organisation would be considered throughout the
remainder of the inspection.

TRIM Ref 2018/0007288
2.2.3 Deployment of ACF lessons learnt within key contractors
94. The ONR inspection team separated into two sub-teams and engaged with key
contractors to assess how NNB GenCo had shared with them the lessons learnt from
the issues at ACF. The following key contractors and associated NNB GenCo project
management staff were involved in the inspection:
 Kier Bam Joint Venture (KBJV)

 BYLOR and their key supplier, Express Reinforcement Supply
 Marine Works contract – Noting that the inspection focussed on the NNB
Project Manager and no contractors were present as Costain were in the
process of demobilisation and handing over to Balfour Beatty.
 Socea Denys
95. ONR noted the following key points from the discussions:
 there was no evidence of the formal sharing of learning associated with the
shortfalls at ACF or NNB GenCo’s ineffective oversight and assurance of this
key supplier.
 lessons had been learnt from the shortfalls associated with the FNSC
substitution layer concrete.
the contractors had an awareness of CFSI risks and positive material
identification sampling was being performed on NNB GenCo’s instruction on
some supplied products (ie copper earthing strip and concrete encast items)
 evidence was available of supplier oversight and assurance activities being
performed below Tier 1 suppliers
 there was an inconsistent approach to Quality Planning/Inspection & Test
Planning and it was noted that NNB GenCo had not produced an exemplar to
guide its key contractors
 evidence was available of supply chain mapping enabling BYLOR to target
supply chain assurance activity on the areas of highest risk. NNB GenCo
detailed that this approach had been led by BYLOR and it was their intent to
utilise similar approaches with other key contractors.
96. It was clear to the ONR inspection team that the issues surrounding the failings at ACF
had not been systematically and effectively promulgated to other key contractors
interviewed as part of this inspection. However, I recognised that there was evidence
of the related learning derived from the similar issues associated with FNSC
substitution concrete pour.
97. ONR reaffirmed their expectation that NNB GenCo should develop adequate supply
chain oversight and assurance that focusses attention on high risk suppliers regardless
of where they are positioned in the supply chain.
98. NNB GenCo’s supply chain self-assessment highlighted shortfalls in the management
system arrangements which could affect safety. I do not consider that the associated
draft improvement plan was adequate, in that it required further development to ensure
that the improvement actions were prioritised, time bound, resourced and aligned to
NNB GenCo’s construction schedule and agreed regulatory permission points.
project wide governance and leadership to ensure that it is prioritised according to
project risks noting that the existing plan places emphasis on the development of the
improvement activities on an individual directorate basis.

TRIM Ref 2018/0007288
100. The self-assessment did not, as I would have expected, identify the apparent shortfalls
in NNB GenCo’s internal assurance programme. For example, internal process audits
had not been carried out by NNB GenCo during 2017 and a future audit programme
was not available.
101. I consider that the learning from the issues surrounding the failings at ACF had not
been promulgated to the key contractors that were interviewed as part of this
inspection. However, I recognise that there was evidence of the related learning
derived from the similar issues associated with FNSC substitution concrete pour.
102. While evidence was available of supply chain mapping within BYLOR’s and SOCEA-
DENYS contracts, it is important that NNB GenCo develop consistent supply chain
oversight and assurance arrangements across the project that focus attention on high
risk suppliers regardless of where they are positioned in the supply chain.
103. From the evidence examined, it was not clear to ONR who, within NNB GenCo, was
responsible for: establishing an effective management system; taking high level
ownership of significant quality issues and associated corrective actions; establishing
and communicating the quality standards appropriate to nuclear build, and for defining
the roles and responsibilities of quality functions across the project to ensure ‘right first
time’ delivery on the construction site. I noted that NNB GenCo was reviewing its
quality organisational arrangements as part of a wider MOC change submission and
intended to address these issues.
2.3 CNI Inspection, Element 3 - Inspection of the Site Command Centre, HPC
Construction Site - 30th November & 1st December 2017
104. This third element of the CNI’s inspection examined:
 how NNB GenCo have shared the lessons learnt from ACF with their other key
contractors;
 changes implemented in key contractors’ arrangements to mitigate the
identified risks;
 how NNB GenCo have strengthened their oversight and assurance
arrangements, their Intelligent Customer role and how this capability will be
maintained;
 the adequacy of deployment of quality standards/requirements at site and their
oversight including adequacy of required quality records and use of quality
plans.
105. The Agenda for this element of the CNI’s Themed inspection was agreed in advance
(TRIM 2017/0456821). The inspection was conducted by four ONR inspectors and
recorded on Contact Record ONR-NR-CR-17-561 (TRIM 2018/0012572).
106. Following opening and overview sessions the inspection team separated in to sub-
teams:
 Team 1 – examined the effectiveness and adequacy of NNB GenCo’s supply

chain oversight/quality management in respect of the main civils contractor
BYLOR which included visiting appropriate construction site areas.
 Team 2 – examined the effectiveness and adequacy of NNB GenCo’s supply
chain oversight/quality management in respect of the earthworks contractor
KierBam which included visiting relevant construction areas.

TRIM Ref 2018/0007288
2.3.2.1 Supply chain management system overview
107. ONR asked NNB GenCo site quality staff to explain what ACF learning had been
communicated to them and how this had been used. NNB GenCo explained that
although they could not recall having received any formal communication related to
learning from ACF, they had taken significant learning from the FNSC substitution
concrete shortfalls.
108. NNB GenCo explained that currently the relationship between the site and central
quality function was not operating as effectively as it could be, potentially due to a lack
of alignment between the central and site quality functions and slow progress with
securing improvements via the HPC Quality Forum. NNB GenCo explained that it
considered that a proposed NNB GenCo reorganisation may address some of the
issues and enable the quality function to perform a more proactive role, driving change
and improvements rather than its current role, focused mainly on oversight.
109. NNB GenCo highlighted that following its FNSC substitution lessons learned activities
it had identified that its guidance on the content of contractors inspection and test
plans could be improved (FNSC Lessons Learned Action Plan (FLLAP):2.5.2 – TRIM
2017/430635). NNB GenCo site quality staff explained that NNB GenCo’s existing
guidance (TRIM 2017/0458365) was considered deficient in a number of areas and
contained ITP exemplars which did not provide appropriate guidance in respect of
expected ITP standards. NNB GenCo had previously highlighted in the DCC
intervention that FLLAP action 2.5.2 was late and explained that this was primarily due
to a communication breakdown regarding the assignment of responsibilities for
addressing the issue. NNB GenCo also explained that the current ITP requirements
were guidance, but it was the opinion of the site based quality personnel that this
should in future be mandatory and contractually required in order to ensure that NNB
GenCo have suitable tools to ensure compliance by its contractors.
110. NNB GenCo provided a copy of an extract from its management system with respect
to quality (TRIM 2017/0458395). It was evident that a number of documents which
ought to be in place to support quality delivery were still under development. NNB
GenCo explained that it considered that currently this was not significantly impacting
the project primarily because the competence and experience of quality leads and
project managers ensures that adequate quality control arrangements are being
applied.
2.3.2.2 Overview of discussions with project managers, quality and construction staff
111. ONR inspection staff engaged with NNB GenCo and site construction staff to examine
the adequacy of NNB GenCo’s supply chain oversight and assurance arrangements.
112. The following key points were noted:
 there was no evidence of the formal sharing of learning associated with the
shortfalls at ACF or NNB GenCo’s ineffective oversight and assurance of this
key supplier as the Intelligent Customer.
 evidence was available within BYLOR and the KBJV of the sharing of lessons
learnt from the shortfalls associated with the FNSC substitution layer concrete.
 NNB GenCo’s supply chain assurance activities had been effective in
identifying shortfalls in BYLOR’s management system arrangements that
required an improvement action plan (TRIM 2017/0458424). Progress to
closure was being driven through the monthly Main Civil Works NNB/BYLOR
quality meetings.
 NNB GenCo highlighted the challenges in ensuring that BYLOR staff
understood the quality requirements on a nuclear site, which were considered a
step change over and above those which would be required on a similar non-

TRIM Ref 2018/0007288
nuclear safety related project. NNB GenCo explained that ensuring that the
BYLOR personnel understood this difference and had the correct nuclear
safety culture had been challenging, however NNB GenCo had started to see
improvements in BYLOR in this area.
 the learning from the FNSC event and subsequent investigations had been
shared with KBJV and resulted in the development of a KBJV improvement
plan (TRIM 2017/0458126). ONR noted that NNB GenCo had paused KBJV
activities at site until it was satisfied with the effectiveness of KBJV early
improvement activities.
 ONR visited the HGS (Relief Well) and HGQ (Effluent Transfer) Gallery
construction area and found the areas to be well controlled with high standards
of general housekeeping. Access to the areas was controlled by a BYLOR
supervisor who provided a thorough and comprehensive safety brief regarding
the hazards in the area.
 ONR visited the Nuclear Island construction area (K18A) and found the
housekeeping at the site was in a good state considering the level of personnel
activity and vehicle movement.
113. NNB GenCo’s organisational learning processes have not ensured that ACF learning
has been communicated in a systematic away throughout the organisation. However,
there was evidence of relevant learning from the FNSC substitution concrete shortfalls
being shared and implemented.
114. NNB GenCo have identified a number of gaps in their management system
arrangements related to quality processes which are still under development. I
consider it important that NNB GenCo reviews its arrangements to ensure that all gaps
are identified and closed in timely manner.
115. NNB GenCo’s planned reorganisation will need to ensure improved alignment between
site and central quality function to ensure effectiveness of the overall quality function.
116. NNB GenCo has identified that it needs to improve its guidance with regards to
Inspection and Test Plans and how they should be consistently implemented. I
consider that this will be beneficial in reducing risk and should ensure that some of the
inconsistencies in implementation identified during this inspection are addressed or
subject to a formal NNB GenCo assessment or approval processes.
117. Both BYLOR and KBJV staff were found to have a good understanding of the
importance of quality standards with appropriate learning from FNSC substitution
concrete. This was evident in the construction site visits undertaken by ONR during
this inspection.
118. Whilst in general quality delivery at site was being appropriately controlled and
overseen by NNB GenCo, in a number of areas NNB GenCo needs to develop its
management system arrangements to reduce reliance on the competence of
individuals. This will ensure that quality management system arrangements are
consistently implemented across the project as it accelerates in terms of work areas
and number of contractors on the site.

TRIM Ref 2018/0007288
2.4 CNI Inspection, Element 4 - Engineering Command Centre, Paris - 30th

November 2017
119. This fourth element of the CNI’s Inspection examined how NNB GenCo had applied
the learning from ACF to the design, procurement and manufacturing processes
relevant to NNB GenCo’s supply chain management. This included:
 production of design specifications and its relevance to NNB GenCo’s oversight

of suppliers;
 explicit learning from ACF on its application to Responsible Designer (RD)/ECC
activities – primarily on manufacturing surveillance approaches by MIT and
CEIDRE/EIRA;
 discussion with contractors on supply chain arrangements.
120. The Agenda for this element of the CNI’s inspection was agreed in advance (TRIM
2017/456858).The inspection was conducted by three ONR inspectors and recorded
on Contact Record, ONR-NR-CR-17-564 (TRIM 2017/466927).
2.4.2.1 Learning for HPC from ACF
121. NNB GenCo outlined the lessons learned from the ACF issues and how these had led
to strengthened approaches being adopted by MIT and CEIDRE. Learning had been
taken from the two separate ACF issues – manufacture & quality challenges identified
in 2014-15, and the historical record anomalies raised in 2016
122. NNB GenCo identified that additional measures had been put in place to enhance the
control of ACF and other NSSS manufacturing, such as greater inspection coverage
and improved NCR reporting. Specific lessons learned and improved arrangements
have been developed for four themes:
 surveillance principles not adequate enough to detect CFSI;

 lack of surveillance penetration;
 insufficient oversight of the supply chain;
 insufficient oversight of Independent Assessment (IA).
123. Both MIT and CEIDRE had undertaken lessons learnt workshops leading to the
enhanced arrangements and revision to CEIDRE inspection guides.
2.4.2.2 Manufacturing oversight
124. NNB GenCo highlighted each of the elements of the overall manufacturing surveillance
approach. This covered each element of the process:
 supplier technical assessment

 mandating & surveillance organisation
 surveillance of documentation
 in-shop inspection
 non-conformances treatment
 end of manufacturing and release of equipment
 manufacturing schedules surveillance
 surveillance of surveillance
 CFSI plan

TRIM Ref 2018/0007288
125. NNB GenCo outlined how CEIDRE performed graded supplier assessments of
potential main contractors and their supply chains on request from NNB GenCo and
based on the supplier risk assessment. This was combined with information from other
NNB GenCo pre-contract assessments (e.g. by QSF auditors, supply chain assurance)
to inform supplier selection and surveillance plans. NNB GenCo identified that the
surveillance process they were now implementing was not in place for oversight of the
ACF contract.
2.4.2.3 Discussion with suppliers
126. NNB GenCo explained the surveillance approach for the UK 3011 contract including
the history of contractor selection. The contract is with General Electric (GE) and is for
the Turbine Hall equipment, including design, manufacturing & installation.
127. GE staff outlined their experience of the contract – and that it had benefited from GE’s
experiences on FA3, Taishan and other NPP projects. GE was cascading NNB
GenCo’s expectations to its supply chain. This included consideration of nuclear safety
culture and the revised GQAS expectations.
128. GE identified that their programme managers had participated in a 5 day workshop
with NNB GenCo on its safety culture expectations. Additionally, GE staff participated
in NNB GenCo’s supply chain event ‘Manufacturing Excellence’ in Paris in November
2017. This had led to a realisation of the need to review and enhance their CFSI
arrangements.
129. Overall, the discussions confirmed application of NNB GenCo’s surveillance

arrangements.
130. As with the DCC element of the CNI Inspection, there was little evidence of explicit
sharing of ACF learning with contractors, RD and NNB teams present at the ECC.
However, I judge that there is evidence that key learning and risk mitigation is being
effectively deployed in NNB GenCo’s supply chain oversight and assurance
arrangements by MIT (NNB GenCo) and CEIDRE.
131. The enhanced processes for supply chain surveillance being developed by CEIDRE
and MIT will be deployed into all HPC projects as routine parts of the Multi-Disciplinary
Team approach. MIT's plan is for the enhanced process to be ready for the end of Q1
2018 which is before the main manufacturing phase for HPC.
132. I consider that MIT and CEIDRE have reviewed the learning from the ACF issues and
have strengthened their processes for supplier risk assessment, surveillance and
inspection.
133. The ongoing adequacy of MIT and CEIDRE’s supply chain oversight and assurance
activities should be examined as part of the project’s routine regulatory workstreams
as the manufacturing activity increases.
3 Conclusions
3.1 Key findings, inspector's opinions and reasons for judgements made
134. Throughout this CNI’s inspection, themes have emerged that relate to both
improvements in NNB GenCo’s processes and to shortfalls in management system
arrangements that, if unresolved, have the potential to affect safety.
135. Initial conclusions and judgements were formed by the ONR inspection teams after
each inspection element. Any preliminary findings identified during these inspection

TRIM Ref 2018/0007288
elements were subsequently considered collectively on completion of the whole

inspection scope, and where regulatory shortfalls were identified, Regulatory Issues
have been raised.
136. I have analysed the key findings and judgements of this CNI’s inspection and consider
that they can be most appropriately defined against the six themes identified in the
sections below.
137. Section 3.1.1 reflects positive progress made by NNB GenCo and its key supplier
Areva and therefore no associated Regulatory Issue is required. However, I will raise
an associated Regulatory Issue as appropriate for each of the themes in sections 3.1.2
to 3.1.6, to define the required improvement activity.
138. The scope of the CNI inspection was specifically targeted at supply chain management
and associated areas. NNB GenCo is currently undertaking work associated with
design, construction and early manufacturing activities. Although arrangements for
control of quality are judged, through ONR’s wider regulatory activities, to be
appropriate at present, this inspection has identified a number of areas where
improvements are required to ensure this position is robustly maintained as the project
progresses and the volume of work and resources required increases.
3.1.1 Areva’s improvement programme
139. The CNI’s inspection placed emphasis on the adequacy of enhanced arrangements at
ACF. The inspection team concluded that ACF and NNB GenCo had made good
progress in deploying their improvement programme and had enhanced their
manufacturing processes, management system arrangements and the facilities’
nuclear safety and quality culture.
140. Overall, I am broadly satisfied with the enhanced management system arrangements. I
note however, as the improvement programme is not yet fully deployed, ACF’s
enhanced arrangements have yet to be fully embedded and therefore will require
continued drive and appropriate oversight and assurance from NNB GenCo as the
Intelligent Customer for the products supplied by ACF, in order to be demonstrated as
sustainable over the longer term.
141. The enhanced arrangements included evidence of strengthened assurance activity

within NNB GenCo’s Manufacturing, Inspection and Testing (MIT) function, and EDF
Group’s CEIDRE (Centre d’Expertise et d’Inspection dans les Domaines de la
Realisation et de l’Exploitation) manufacturing inspection department, that will be
essential as the equipment manufacturing programme accelerates as the project
progresses.
142. I recommend that ONR continue to assess NNB GenCo’s and Areva’s progress
through the existing ‘Areva Manufacturing’ regulatory workstream.
3.1.2 Learning associated with shortfalls at ACF
143. Evidence was not provided during the inspection to demonstrate how NNB GenCo had
captured all the key learning from the issues associated with the failings at ACF, and
ensured its effective promulgation to NNB GenCo’s key contractors interviewed as part
of this inspection. I did however recognise that evidence was available of the learning
for site contractors from the similar issues associated with First Nuclear Safety
Concrete (FNSC) substitution concrete pour.
144. The CNI Inspection scope emphasised that it would consider the effective deployment
of lessons for other key contractors. Therefore, I consider it important that NNB GenCo

TRIM Ref 2018/0007288
evaluate how it has captured the key learning from the shortfalls at ACF and consider if
it has been effectively promulgated within its organisation and its key contractors.
3.1.3 Supply chain self-assessment improvement programme
145. I consider that NNB GenCo’s improvement plan, derived from of its supply chain self-
assessment, requires further development as the version provided to the ONR
inspection team was not effectively prioritised, time bound, resourced and aligned to
the HPC construction schedule and agreed regulatory permissioning points. I am of the
view that this version is not adequate given that improvement activities relate to
shortfalls in management system arrangements which, if unresolved, have the
potential to affect safety.
project wide governance and leadership to ensure that it is prioritised on project risks,
noting that the existing plan places emphasis on the development of the improvement
activities on an individual directorate basis.
3.1.4 Quality Management System shortfalls
147. This inspection has found shortfalls in NNB GenCo’s quality management system
arrangements related to supply chain management activity. Some shortfalls were
identified during NNB GenCo’s supply chain self-assessment activity performed in
advance of this inspection. However, this CNI’s inspection identified the following
management system shortfalls that will require resolution:
 Inspection & Test Plans (ITPs) - NNB GenCo has identified that it needs to
improve its guidance with regards to the preparation and use of ITPs and that
they should be consistently implemented. I consider that this will be beneficial
in reducing construction quality risks and should ensure that some of the
inconsistencies in implementation identified during this inspection are
addressed or subject to a formal NNB GenCo assessment or approval
processes.
 Internal Assurance Programme – The supply chain self-assessment did not
identify shortfalls in NNB GenCo’s internal assurance programme, which the
CNI’s inspection team subsequently identified. The assurance function had not
completed any internal process audits during 2017, with no future audit
programme available. The lack of an internal process assurance programme
was disappointing as an effective programme may have prevented many of the
shortfalls identified both in the supply chain self-assessment and in this
inspection.
 Supply Chain Assurance - The CNI inspection team identified potential risks
with NNB GenCo’s oversight and assurance arrangements for work sub-
contracted by their Tier 1 suppliers at both ACF and with site contractors. I
have challenged NNB GenCo to ensure that their approach is commensurate
with risk, regardless of where it arises in the supply chain, rather than being
focussed on Tier 1 suppliers.
148. I consider that further development of NNB GenCo’s management system

arrangements is important to reduce reliance on the competence of individuals to
compensate for lack of procedural clarity. This shortfall was highlighted on the
construction site related to the ITPs and gaps in project quality documentation.
Addressing this should ensure that quality management system arrangements are
consistently implemented across the project as it accelerates and the work and
number of contractors on site increases.

TRIM Ref 2018/0007288
3.1.5 Roles & responsibilities for quality
149. The CNI inspection team found a lack of clarity over the project wide leadership of
NNB GenCo’s quality organisation and who had the responsibility for establishing an
effective management system and communicating the quality standards, roles and
responsibilities across the project to ensure ‘right first time’ delivery on the construction
site.
150. I noted during the inspection that NNB GenCo were in the process of reviewing their
quality organisational arrangements as part of a wider Management of Organisational
Change submission. I consider it important that this change clarifies the roles and
responsibilities for quality delivery on the project and enhances the coordination
between the site and supporting quality functions.
3.1.6 Internal assurance activities
151. This CNI inspection has identified shortfalls in supply chain management system
arrangements important to safety and roles and responsibilities important to safety.
152. The supply chain self-assessment completed by NNB GenCo prior to this CNI
inspection identified a number of additional shortfalls that require resolution.
153. Given the conclusions of the CNI inspection, I consider that NNB GenCo should further
review its current project assurance arrangements and consider appropriate areas for
improvement.
3.2 Inspector’s rating
154. The individual findings from the various elements of this CNI Inspection highlight a
number of deficiencies in NNB GenCo’s management system arrangements. These
individual deficiencies, taken on their own, may not be of such seriousness to raise a
regulatory issue; however in aggregation they indicate a broader deficiency in NNB
GenCo’s arrangements and I judge that overall five Regulatory Issues, aligned with the
thematic shortfalls identified above, should be raised.
155. I have concluded that these Issues represent shortfalls against LC 17 – Management
Systems.
156. Through its wider regulatory interventions, ONR consider that current arrangements,
coupled with the competence of personnel, are capable of managing current
workscope. However, they may not be sufficient as the project moves forward and
work volumes and required resources increase. There is a need, therefore for NNB
GenCo to develop these arrangements further to provide sustainable control as the
work expands.
157. The Regulatory Issues identified represent a failure to implement or meet compliance
arrangements and therefore I am allocating an Inspection rating of Amber – Below
Standard.
3.3 Conclusion of intervention
158. This CNI’s inspection has achieved its purpose and was efficiently and effectively
delivered to plan as defined in the approved project task sheet (TRIM 2017/313658).
159. The differing elements of the inspection involved a total of eleven ONR inspectors with
two ASN inspectors observing while at ACF. The significant number of NNB GenCo
and its supply chain staff engaged with as part of this inspection demonstrates the
scale, strategic nature and safety significance of the inspection scope.

TRIM Ref 2018/0007288
160. NNB GenCo has successfully facilitated this inspection with the support of its supply
chain ensuring that each element of the inspection achieved its purpose. This involved
considerable coordination with ONR in advance of, and during the inspection. I
anticipate that this positive support will continue as the issues raised in this inspection
are resolved.
161. The purpose of this supply chain focussed CNI’s inspection was to assess the
adequacy of NNB GenCo’s supply chain management arrangements including
oversight and assurance and improvement action plan, specifically focussed on:
 the effective deployment of lessons for other key contractors and the
enhancement to NNB GenCo’s supply chain oversight and assurance
arrangements
 the effective deployment of Areva’s improvement programme, specific to ACF
and associated manufacturing facilities
 the adequacy of Areva’s enhanced manufacturing processes - informed by the
Nuclear Steam Supply System (NSSS) workstream and supported by ONR’s
Structural Integrity team
 improvements to ACF’s nuclear safety and quality culture
 effective deployment of NNB GenCo’s associated organisational changes
162. I consider that this CNI’s Inspection has achieved its purpose and efficiently and
effectively assessed the identified scope.
163. The CNI inspection was performed in the early stages of NNB GenCo’s construction
and manufacturing programmes. The timing will allow NNB GenCo to address the
identified shortfalls prior to the acceleration of HPC construction and manufacturing
activity.
164. The inspection has identified five thematic shortfalls which will each be tracked to
closure through an associated Regulatory Issue. The resolution of these issues will
help mitigate the risk of substandard manufacture and construction quality and
potential impacts to the construction schedule and ONR’s project permissioning
decisions. They may also make a positive contribution to the safe and reliable
operation of the HPC Nuclear Power Plant during its operational phase.
165. I consider that the with the correct application, NNB GenCo will be able to implement
the required improvements and close the five Regulatory Issues in advance of
regulatory assessments associated with the Nuclear Island Concrete permissioning
point currently scheduled for August 2018.
166. Timely resolution of the identified issues will reduce project risk and contribute to NNB
GenCo’s aim of quality, ‘right first time’ delivery.
4 ISSUES
4.1 Issues Raised
Issue Licensee/Duty Holder Owner Completion /

No Issue Title Category
Level Role (Inspector) Review Date
6144 Learning Associated 3 NNB GenCo (HPC) 29th June 2018
with Shortfalls at ACF
6145 Improvements required 3 NNB GenCo (HPC) 29th June 2018
to Supply Chain Self-
Assessment
Improvement
Programme

TRIM Ref 2018/0007288

6146 Quality Management 3 NNB GenCo (HPC) 29th June 2018
System Shortfalls
6147 Roles & 3 NNB GenCo (HPC) 29th June 2018
Responsibilities for
Quality
6148 Internal Assurance 3 NNB GenCo (HPC) 29th June 2018
Activities
4.2 Issues Closed

RECORD APPROVAL, SIGN-OFF AND ISSUE
RECORD APPROVAL AND SIGN-OFF

Executive
Revision Name Responsibility Summary Date
Approved
0 Author 26 February 2018
1 Superintending 26 February 2018

Inspector
VERSION CONTROL
Revision Date Description of Change

0A 1st draft incorporating inspection team comments
0B 26/01/18 2nd draft incorporating NNB GenCo factual accuracy review comments
0C 08/02/18 3rd draft incorporating peer review comments
0D 20/02/18 4th draft incorporating NNB GenCo & approver comments
1 26/02/18 1st Issue
CIRCULATION LIST
Organisation Name / Responsibility Date

Office for Chief Nuclear Inspector 26 February
Nuclear Deputy Chief Nuclear Inspector & 2018
Regulation Director of New Reactor Construction

TRIM Ref 2018/0007288
Superintending Inspector & Head of EPR

Construction
Principal Inspector & Supply Chain and
Quality Professional Lead
Superintending Inspector & Head of
AP1000 Construction
Specialist Nuclear Inspector, Structural
Integrity
Specialist Nuclear Inspector, Structural
Integrity
Principal Inspector & HPC Site Inspector
Principal Inspector & HPC Organisational
Capability Cornerstone Lead
Specialist Nuclear Inspector, Supply
Chain & Quality
Specialist Nuclear Inspector, Supply
Chain & Quality
Superintending Inspector & Regulatory
Oversight Manager
Principal Inspector & Head of Regulatory
Intelligence
Principal Inspector & HPC Project
Inspector
ONR Communications
TRIM File 4.4.2.18345.

TRIM Ref 2018/0007288
APPENDIX 1 -PRINCIPAL STAFF SEEN
Areva Creusot Forge
NI Programme Manager, NNB GenCo

NSSS Programme Manager, NNB GenCo
Manufacturing Inspection Team, NNB GenCo
NSSS Quality, NNB GenCo
Safety and Assurance Director, NNB GenCo
Areva Creusot Forge, HR
Areva Creusot Forge, Commercial Manager
Areva Creusot Forge, Quality Manager
Areva Creusot Forge, Site Director
Areva Creusot Forge, Technical Director
Areva Creusot Forge, Production Manager
Areva Creusot Forge, Technical Manager
CEO Areva Component Manufacturing
S&Q Manager, Areva Component manufacturing
Areva NP, Component Manufacturing
, Areva NP, UK EPR Quality Manager
Areva NP, NHPS Project Manager
CEIDRE, EDF
ITPIA, Lloyds-Apave
Delivery Command Centre
Managing Director, NNB GenCo

Safety and Assurance Director, NNB GenCo
Supply Chain Director, NNB GenCo
Technical Director, NNB GenCo
Regulatory and Licensing Manager, NNB GenCo
Site Nuclear Compliance Manager, NNB GenCo
Head of Quality Systems, NNB GenCo
Head of MIT, NNB GenCo
Commercial Lead, Supply Chain, NNB GenCo
IACO, NNB GenCo
Main Civils Programme Manager, NNB GenCo
Earthworks Senior Project Manager, NNB GenCo
NSSS Senior Project Manager, NNB GenCo
Civils Hold Point Manager, NNB GenCo
Regulatory and Licensing, NNB GenCo
Senior Construction Lead, NNB GenCo
Head of Assurance, NNB GenCo
Quality Audit and Improvement, NNB GenCo
Quality Lead, NNB GenCo
Enabling Programme Manager, NNB GenCo
Lead Commercial Civil, NNB GenCo
HS & BoP Programme Manager, NNB GenCo
Commercial Lead, NNB GenCo
Senior Project Manager BoP, NNB GenCo
Senior Quality Lead, NNB GenCo
Project Manager (CRF) , NNB GenCo
Quality Lead (CRF), NNB GenCo
Commercial (CRF), NNB GenCo
Commercial Director, KBJV

TRIM Ref 2018/0007288
Project Director, KBJV

Senior Construction Manager, KBJV
Head of Quality, KBJV
Section Manager, Deep Dig, KBJV
Technical Director, BYLOR
Quality Lead, BYLOR
Reinforcement Project Manager, BYLOR
Construction Director, BYLOR
Commercial Manager, Express Reinforcements Ltd
Quality Manager, Express Reinforcements Ltd
Project Manager, SOCEA-DENYS
QSHE Manager, SOCEA-DENYS
Engineering Command Centre
Engineering Director, NNB GenCo

Head of MIT, NNB GenCo
ECC Manager & Deputy Head of Owners
Engineering, NNB GenCo
MIT, NNB GenCo
MIT, NNB GenCo
Sequence Lead, Owners Engineering, NNB
GenCo
Equipment Design & Procurement Sequence Lead,
NNB GenCo
Owners Engineering, NNB GenCo (by phone)
CI Programme Manager, NNB GenCo
CI Manufacturing Surveillance Lead, NNB GenCo
Technical Head, HPC Project, CNEN
Head of CW Design, EDVANCE,
Conventional Island Team Lead, CNEPE
Délégué Affaires et Projects, CEIDRE
Head of EMIB, CEIDRE
Project Lead, CEIDRE
ICOS Project Director
Project Manager, GE
Project Sourcing, GE
Site Command Centre
Construction Delivery Lead, NNB GenCo

Construction Delivery Lead Galleries, NNB GenCo
KBJV Project Director
Senior Project Manager Earthworks, NNB GenCo
Senior Project Manager Main Civil Work, NNB
GenCo
KBJV Construction Director
KBJV Head of Quality
KBJV Senior Construction Manager
BYLOR Principal Engineer
BYLOR Project Engineer
BYLOR Quality Lead
Enabling Programme Manager, NNB GenCo
Galleries Project Manager, NNB GenCo

TRIM Ref 2018/0007288
Senior Quality Lead, NNB GenCo

Quality lead, NNB GenCo
CRF Quality Lead, NNB GenCo
Project Manager Earthworks, NNB GenCo
Construction Director, NNB GenCo
Quality lead, NNB GenCo
Site Nuclear Compliance Manager, NNB GenCo
IACO Assurance, NNB GenCo
IACO Assurance, NNB GenCo
NNB Galleries Project Manager, NNB GenCo
Main Civils Quality Lead, NNB GenCo
Area Construction Delivery Manager Earthworks,
NNB GenCo
Senior Project Manager Earthworks, NNB GenCo
Enabling Works Quality Lead, NNB GenCo
BYLOR Quality Engineer
BYLOR Fieldview Administrator
BYLOR Technical Director
BYLOR Principal Engineer,
Project Manager Technical Galleries, NNB GenCo
Regulatory Interface Office, NNB GenCo
Regulatory Interface Office, NNB GenCo
KBJV Agent
KBJV Sub-Agent
KBJV Section Engineer
KBJV Quality Lead
Construction Delivery Lead
BYLOR Non-Working Supervisor
BYLOR Project Manager Galleries
Regulator Interface Officer, NNB GenCo
KBJV Quality Lead
Regulatory Interface Officer, NNB GenCo
KBJV Section Engineer
KBJV Deep Dig Construction Manager

ONR Chief Nuclear Inspector Report of EDF Energy and Hinkley Point C Supply Chain

Enviado por

Dados do documento

Título original

Direitos autorais

Formatos disponíveis

Compartilhar este documento

Compartilhar ou incorporar documento

Opções de compartilhamento

Você considera este documento útil?

Este conteúdo é inapropriado?

Direitos autorais:

Formatos disponíveis

ONR Chief Nuclear Inspector Report of EDF Energy and Hinkley Point C Supply Chain

Enviado por

Direitos autorais:

Formatos disponíveis

Title of document

PRINCIPAL STAFF SEEN

(B) INTERVENTION RATINGS

2.1 LC 17 Planned Inspection NNB GenCo (HPC) 17 Amber P

Office for Nuclear Regulation Page 2 of 30

1 EXECUTIVE SUMMARY ..................................................................................................... 4

Office for Nuclear Regulation Page 3 of 30

1.1 Purpose of intervention - Inspection aims & approach

2. ONR had previously participated in a multinational inspection of ACF during

1.2 Purpose of CNI sponsored inspections

8. As described in ONR Guide ONR-INSP-GD-059 Rev. 5, CNI inspections differ from

Office for Nuclear Regulation Page 4 of 30

potential safety or security significance, or having the potential to adversely impact

1.3 Interventions carried out by ONR

Office for Nuclear Regulation Page 5 of 30

1.4.1 Areva’s improvement programme

19. The enhanced arrangements included evidence of strengthened assurance activity

1.4.2 Learning associated with shortfalls at ACF

1.4.3 Supply chain self-assessment improvement programme

1.4.4 Quality Management System shortfalls

Office for Nuclear Regulation Page 6 of 30

identified during NNB GenCo’s supply chain self-assessment activity performed in

26. I consider that further development of NNB GenCo’s management system

1.4.5 Roles & responsibilities for quality

1.4.6 Internal assurance activities

Office for Nuclear Regulation Page 7 of 30

1.5 Inspector’s rating

1.6 Conclusion of intervention

Office for Nuclear Regulation Page 8 of 30

regulatory assessments associated with the Nuclear Island Concrete permissioning

Office for Nuclear Regulation Page 9 of 30

2.1.1 Inspection element objectives

44. This first element of the CNI’s inspection examined:

 The effective deployment of Areva’s improvement programme, specific to ACF

45. The inspection was recorded on Contact Record, ONR-NR-CR-17-452 (TRIM

2.1.2 Summary of inspection activity

 Team 1 – Examined organisational changes; management system and nuclear

2.1.2.1 Organisational changes

Office for Nuclear Regulation Page 10 of 30

2.1.2.3 Third & second party inspection organisations

2.1.2.4 Development of forging processes

58. ACF demonstrated their Technical Manufacturing Programme (TMP) based on a

Office for Nuclear Regulation Page 11 of 30

2.1.2.5 Machining & testing operations

2.1.2.6 Enhancements to the non-conformance & deviation control processes

2.1.3 Key findings & judgements

Office for Nuclear Regulation Page 12 of 30

2.2 CNI Inspection, Element 2 - Inspection of Delivery Command Centre, Bristol -

2.2.1 Inspection element objectives

71. This second element of the CNI’s inspection examined:

2.2.2 Summary of inspection activity

2.2.2.1 Opening meeting

Office for Nuclear Regulation Page 13 of 30

2.2.2.2 NNB GenCo’s supply chain process self-assessment

Office for Nuclear Regulation Page 14 of 30

2.2.2.3 NNB lessons learnt from ACF

2.2.2.4 Project quality standards & development of supply chain quality

Office for Nuclear Regulation Page 15 of 30

2.2.3 Deployment of ACF lessons learnt within key contractors

 Kier Bam Joint Venture (KBJV)

2.2.4 Key findings & judgements

Office for Nuclear Regulation Page 16 of 30

2.3.1 Inspection element objectives