Executive summary
Date(s) of inspection: April 2024
Aim of inspection
The aim of the inspection was to assess the adequacy of NNB Generation Company (HPC) Ltd's (NNB GenCo) arrangements for compliance with pressure regulations, in relation to its principal manufacturer of pressure systems pipework for Hinkley Point C (HPC), Bilfinger Nuclear & Transmission GmbH (BNET) at Dortmund, Germany.
The inspection objectives were to examine, but not limited to, the implementation of arrangements and the licensee's capability in:
- promotion and implementation of PSSR (Pressure Systems Safety Regulations) Safety Case Policy (PSCP) requirements in the supply chain, especially in relation to Bilfinger;
- implementation of the PSCP via sampling of a specific manufactured product to be used at HPC;
- providing adequate oversight of preparatory arrangements as informed by Bilfinger during transport, storage and site installation, as covered by the PSCP; and
- inclusion of operational experience (OPEX) from the supply chain to inform appropriate improvements to the PSCP.
Bilfinger will also be manufacturing the main steam line (MSL) for HPC, which is a highest integrity component requiring beyond the standard nuclear design/inspection code requirements; the PSCP provides the foundational basis for those requirements too.
Subject(s) of inspection
- LC19 - Construction or installation of new plant - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
During the inspection I witnessed how the PSCP requirements are captured in various licensee documents and how that informs the inspection plans and trackers to check for conformity for its nuclear steam supply systems (NSSS), balance of nuclear island (BNI) and balance of plant (BOP) scopes. I saw evidence of licensee’s quality assurance requirements being incorporated into BNET’s quality assurance (QA) documents to ensure consistency with the requirements and expectations, including sharing and dissemination of OPEX.
For this inspection I sampled the BNI scope. I observed that significant interactions take place between the stakeholders to arrive at the 'as build' configuration. I therefore judged that this satisfied broad requirements of Section 6 and 7 of the PSCP. However, I identified a potential shortfall with configuration management and control and have asked the licensee to provide further information.
I sampled the implementation of elements of Section 7 of the PSCP with BNET’s documentation and actual fabrication activities, and noted evidence of material traceability across spools that corroborated with the information available on the relevant follow-up documents (FuDs). I observed that BNET applies good control on traceability of parts during fabrication activity and storage, including demonstrably good foreign material exclusion (FME) controls. I sampled a welding activity and observed that BNET applied suitable control, monitoring and assistance during the operation.
I observed that the preparation of the FuDs, which ultimately are captured in the end of manufacturing report (EoMR), is completely paper based, whilst colour coded (blue for BNI/ferritic and yellow for BNI/austenitic) and manually driven. I raised with the licensee that this could be susceptible to counterfeit, fraudulent and suspect items (CFSI) activities, which they were already aware.
Noting some anomalies with segregation on pipes in the shopfloor, I asked the licensee to provide details of its mitigation strategy on the risk of cross contamination of stainless steel products from the ferritic components.
Overall, I was content that I saw evidence which underpins some of the requirements of Sections 6 and 7 of the PSCP, and Section 7.1 of the Competent Persons Inspection Requirements (CPIR).
I also sampled evidence of overall PSCP surveillance plan (Sections 6.9 and 7.6) provided by the Internal Inspection Agency (IIA) on behalf of the licensee, wherein the trackers identity the links with the requirements of the PSCP and CPIR (Section 7.2) with the activities actually witnessed. I also sampled IIA’s processing of non-conformances, although no formal non-conformance reports (NCRs) have been raised so far.
I also witnessed IIA inspector witnessing specific fabrication activities at the workshops, particularly with respect to sacrificial pipework wherein the External Inspection Agency (EIA) and Direction Industrial (DI) were also involved. This gave me confidence there is adequate surveillance provided by the licensee following its own requirements as enshrined in the PSCP/CPIR.
For this inspection I sampled the BNI scope. I observed that significant interactions take place between the stakeholders to arrive at the 'as build' configuration. I therefore judged that this satisfied broad requirements of Section 6 and 7 of the PSCP. However, I identified a potential shortfall with configuration management and control and have asked the licensee to provide further information.
I sampled the implementation of elements of Section 7 of the PSCP with BNET’s documentation and actual fabrication activities, and noted evidence of material traceability across spools that corroborated with the information available on the relevant follow-up documents (FuDs). I observed that BNET applies good control on traceability of parts during fabrication activity and storage, including demonstrably good foreign material exclusion (FME) controls. I sampled a welding activity and observed that BNET applied suitable control, monitoring and assistance during the operation.
I observed that the preparation of the FuDs, which ultimately are captured in the end of manufacturing report (EoMR), is completely paper based, whilst colour coded (blue for BNI/ferritic and yellow for BNI/austenitic) and manually driven. I raised with the licensee that this could be susceptible to counterfeit, fraudulent and suspect items (CFSI) activities, which they were already aware.
Noting some anomalies with segregation on pipes in the shopfloor, I asked the licensee to provide details of its mitigation strategy on the risk of cross contamination of stainless steel products from the ferritic components.
Overall, I was content that I saw evidence which underpins some of the requirements of Sections 6 and 7 of the PSCP, and Section 7.1 of the Competent Persons Inspection Requirements (CPIR).
I also sampled evidence of overall PSCP surveillance plan (Sections 6.9 and 7.6) provided by the Internal Inspection Agency (IIA) on behalf of the licensee, wherein the trackers identity the links with the requirements of the PSCP and CPIR (Section 7.2) with the activities actually witnessed. I also sampled IIA’s processing of non-conformances, although no formal non-conformance reports (NCRs) have been raised so far.
I also witnessed IIA inspector witnessing specific fabrication activities at the workshops, particularly with respect to sacrificial pipework wherein the External Inspection Agency (EIA) and Direction Industrial (DI) were also involved. This gave me confidence there is adequate surveillance provided by the licensee following its own requirements as enshrined in the PSCP/CPIR.
Conclusion
Overall, based on the information presented by the licensee, BNET and others, along with witnessing fabrication and surveillance activities at BNET’s workshop, I was content that the relevant requirements from the PSCP and CPIR have been sufficiently demonstrated to ensure compliance. I was also content that the licensee has carried out adequate surveillance of the activities that demonstrated PSCP compliance.
I consider that, in accordance with ONR guidance on the application of inspection ratings, a GREEN rating (no formal action) against Licence Condition 19 (construction or installation of new plant) is appropriate for this inspection. The actions raised with the licensee will be tracked via normal business.
I consider that, in accordance with ONR guidance on the application of inspection ratings, a GREEN rating (no formal action) against Licence Condition 19 (construction or installation of new plant) is appropriate for this inspection. The actions raised with the licensee will be tracked via normal business.