Reaching a new standard

ALL NUCLEAR FACILITIES, IRRESPECTIVE OF their size or function, must provide evidence of compliance against international codes and standards as appropriate to their facility. This must be applied in a manner which is proportionate to the harm potential of the facilities in question.

The capability for safe nuclear power operation should be verified in the plans and arrangements for effective control, which begins with the verification of supply chain capability for safe design, manufacture, commissioning and decommissioning.

This includes demonstrating that a good safety culture and an organisational baseline exists within the supply chain, both of which are designed to provide evidence of a full suite of suitably qualified and experienced persons (SQEP), together with suitable and sufficient safety documentation to provide clear and unambiguous confirmation that components can be manufactured and operated to the required safely standards.

In order to demonstrate organisational capability against regulatory requirements, TSP Engineering invited Nuclear CC to review its current working practices and those of its supply chain. Global nuclear suppliers are required to verify that applicable standards are fully embedded within their people and processes. An integrated management system is accepted as the best way of demonstrating this organisational capability.

Nuclear CC conducted a comprehensive and detailed assessment of TSP Engineering’s organisational capability against ISO 19443 and the UK nuclear regulatory requirements for the development and manufacture of reactor components.

The assessment was conducted to assess the company’s current status in the supply of goods and services, address any shortfalls identified and ensure the requirements of the UK nuclear industry are fully understood via the ISO 19443:2018 standard. During the assessment, a review of the organisations management system was carried out in order to demonstrate current working practices and the interface between people and processes, including responsibilities for safety and quality.

The assessment was used as a tool to make improvement measures within the company and its supply chain and as a method of implementing continuous improvement and best available techniques. Cognisance was taken of, but not limited to:

• ISO 19443:2018
• Technical Assessment Guide 77
• Nuclear Industry Code of Practise - NICOP
• HSE Safety Assessment Principles – SAPs
• ASME – NQA-1
• RCC-M – A5000

The checklist used during the assessment, adapted to include nuclear regulatory requirements specific to the company, covered:

• Contract review
• Design
• Software quality assurance
• Procurement
• Manufacturing/ and assembly activities, material control, handling, storage and delivery
• Special processes
• Test, inspection and calibration
• Document control
• Organisation
• Non-conforming Items
• Internal audit
• Corrective action
• Training and certification
• Post delivery
• Records

The assessment included an in-depth review and detailed analysis of current working practices and included the competence of each person performing activities in all relevant disciplines from commercial to finance.

Discussions conducted during the assessment identified a number of improvements and challenges that had to be met. These turned into real opportunities: the recently implemented agility management system; introduction of a ‘SOFT’ reporting structure; an improvement initiative implemented under the governance of Nuclear CC to show that organisational capability can be demonstrated; a detailed training matrix; and implementation of suite of updated role and competency profiles using the nuclear industry best practice, including verifying succession planning.

TSP Engineering underwent a series of training sessions specific to each discipline, including: ISO 19433 awareness; internal auditor; and process review against nuclear industry requirements. It produced a ‘drop down list’ against each code and standard as appropriate to each function. Personnel from all disciplines discussed their area of accountability against the requirement of ISO 19443. Ownership, accountability and responsibility was firmly embedded in each discipline, resulting in a deep understanding of their respective responsibilities and increasing their awareness and of nuclear industry codes and standards.

Potential growth was considered, as was export potential and expanding the level of compliance into the supply chain via a series of on-site events. TSP Engineering has now been recognised with a ISO 19443 certification.

About ISO 19443

Fundamental to the nuclear supply chain is the ability to supply goods and services to the required quality standard, determined by the safety significance, categorisation and classification of supplied products.

The aerospace and automotive industries have specific standards to ensure quality and safety of their products, these are under ISO 9100 and ISO/TS16949, both of which are based on ISO 9001. But the nuclear industry had no specific standard and relied solely on the 9001 standard as a baseline for supply chain nuclear quality and safety.

ISO 9001:2015 was a significant improvement on the 2008 standard, due to the inclusion of ‘Context of the Organisation’ and ‘Interested Parties’, but it relied on the supply chain’s understanding of interested parties.

ISO 19443 applies the principles of ISO 9001:2015 to the nuclear sector and also takes due cognisance of the International Atomic Energy Agency (IAEA) Safety Standard – General Safety Requirements Part 2, Leadership and Management for Safety, (more commonly known as GSR Part 2), which states under requirement 11:

• The organisation (licensee) shall put in place arrangements with vendors, contractors and suppliers for specifying, monitoring and managing the supply to it of items, products and services that may influence safety.
• The organisation shall retain responsibility for safety when contracting out any processes and when receiving any item, product or service in the supply chain.
• The supply chain, described as ‘suppliers’, typically includes designers, vendors, manufacturers and constructors, employers, contractors, subcontractors, and consigners and carriers who supply safety related items.
• The supply chain can also include other parts of the organisation and parent organisations.
• The organisation shall have a clear understanding and knowledge of the product or service being supplied.
• The organisation shall itself retain the competence to specify the scope and standard of a required product or service, and subsequently to assess whether the product or service supplied meets the applicable safety requirements.
• The management system shall include arrangements for qualification, selection, evaluation, procurement, and oversight of the supply chain.
• The organisation shall make arrangements for ensuring that suppliers of items, products and services important to safety adhere to safety requirements and meet the organisation’s expectations of safe conduct in their delivery.

Main Image: TSP Engineering’s Workshop