Office for Nuclear Regulation

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Compliance and Inspection LC21 & LC26

Executive summary

Purpose of intervention

The purpose of this intervention was to undertake a Licence Condition (LC) compliance inspection at EDF Energy Nuclear Generation Limited (NGL) Heysham 2 power station in line with the planned inspection programme contained in the Heysham 2 Integrated Intervention Strategy (IIS).

Interventions Carried Out by ONR

This intervention included compliance inspections against the following Licence Conditions (LC):

The inspection undertaken utilised the following ONR guidance documents:

These guidance documents require inspectors undertaking compliance inspections against these LCs to consider both the arrangements that are in place together with their associated implementation.

Explanation of Judgement if Safety System Not Judged to be Adequate

No safety system inspection was undertaken, hence this is not applicable.

Key Findings, Inspector's Opinions and Reasons for Judgements Made

The process for commissioning modifications to existing plants cites the corporate guidance as well as local arrangements.  NGL identified shortfalls in the process within the corporate arrangements associated with a lack of specific guidance in relation to commissioning modifications to existing plant; however the local arrangements require those performing modifications to include testing/ commissioning proposals within the safety case for the modification.  The shortfall in the corporate arrangements was also identified by ONR at Heysham 1 and as a result a corporate ONR Issue has been raised to address the shortfall.  Recognising that the local arrangements adequately address commissioning for modifications to existing plant, I was content that the arrangements in this area were adequate.

I then elected to sample implementation of the arrangements through inspection of a modification to existing plant, namely the installation of the Variable Speed Drives (VSDs) on the gas circulators.  I inspected the process for the testing/commissioning within the safety case, which captured the requirement for a commissioning test schedule as well as the need for a Testing and Commissioning Panel (T&CP) and a Project Safety Review Group (PSRG) to be established.  The commissioning quality plan was sampled to ensure that the process had been implemented in accordance with the arrangements in place.  As a result I have confirmed through my sample that the arrangements under LC21 have been implemented accordingly. 

From an LC21 perspective, based on the evidence sampled during this inspection, I consider the arrangements and implementation were to an adequate standard and as a result I have rated this element of my inspection through the IIS as 3 (adequate).

The following areas were included as part of the LC26 inspection:

I elected not to focus on the specific arrangements associated with LC26 as these have been subject to inspection over the past two years (ONR-HYB-IR-12-019, ONR-HYB-IR-13-008, ONR-HYB-IR-13-031, and ONR-HYB-IR-14-187 refer).  Rather I considered the implementation of the arrangements in the following areas:

I performed a detailed sample of the work instructions, control of the work, safety document compliance and oversight for a number of tasks for the above two areas.  From discussions with the technicians there appeared to be sufficient supervision of the work to ensure that it was being completed in accordance with the instructions in place.  I made a number of minor observations and potential areas for improvement in relation to checksheet completion and extent of detail contained therein.  I am content for NGL to address these observations through their normal arrangements and consider that these can be captured as part of normal regulatory business without the need for an ONR Issue to be raised.

From an LC26 perspective, based on the evidence sampled during this inspection I consider the arrangements to have been implemented to an adequate standard and I have rated this element of my inspection an IIS rating of 3 (adequate).

The intervention was performed in line with ONR’s guidance requirements (as described in our technical inspection guides) in the areas inspected.

Conclusion of Intervention

Overall I considered that the arrangements and their associated implementation for both Licence Conditions inspected met the requirements of ONR guidance and have rated both through the IIS as 3 (adequate). 

There are no findings from this inspection that could significantly undermine nuclear safety and no change to the planned interventions and inspections of Heysham 2.