Under Licence Condition 30 (3) the licensee, EDF Energy Nuclear Generation Limited (NGL) require consent from the Office for Nuclear Regulation (ONR) to start up Hartlepool Reactor 2 after a periodic shutdown. I have undertaken this intervention to inspect the civil engineering aspects of the Reactor 2 pre-stressed concrete pressure vessel inspection and maintenance programme.
This intervention was in accordance with ONR's planned inspection programme contained in the Hartlepool 2016 Reactor 2 Shutdown - Regulatory Station Outage Plan.
My intervention evaluated compliance with Licence Condition 28 (examination, inspection, maintenance and testing) by sampling the following activities:
The main purpose of the examinations, inspections, maintenance and tests is to provide evidence in support of the Appointed Examiner's judgement on whether the pre-stressed concrete pressure vessel remains fit for continuing operation.
Overall I judged from the sampled activities and the records provided that:
The examination, maintenance, inspection and testing activities for the pre-stressing and leak searching and sealing activities were being carried out in accordance with adequate arrangements. I found the arrangements to be comprehensive and detailed and observed a high degree of understanding of the requirements both from NGL's and the contractor's staff.
NGL was providing adequate control and supervision of the pre-stressing contractor. My judgement is based on the regular contact I observed between the NGL supervisor and the contractor's supervisor and other staff and the detailed arrangements that enable NGL to have effective oversight of the contractor's work.
The pre-stressing contractor's supervisors and operatives were suitably qualified and experienced. My judgement is based on a review of the contractor's training records and my discussions with the contractor's team leader and with the NGL Quality Management department.
The Appointed Examiner was carrying out an appropriate degree of independent oversight of the pre-stressing activities. My judgement is based on detailed discussions with the APEX and on sampling the APEX Branch instructions. The Branch Instructions have been produced to a high standard and the APEX demonstrated a very thorough knowledge of their requirements and was implementing them appropriately.
I considered that the tendon selections for load testing and withdrawal are adequate.
I observed some minor anomalies in the contractor's procedures and some areas of misalignment between the contractor's procedures and the Appointed Examiner's Branch Instructions. I brought these anomalies to NGL's attention and I am content to follow them up as part of normal regulatory business.
I considered that improvements can be made to protect replacement tendons, to prevent possible damage and the acquisition of debris prior to the tendon entering the duct. I have raised an appropriate action on NGL and entered this onto ONR's issues database to ensure it can be adequately tracked to completion.
I observed that improvements to edge protection and housekeeping arrangements can be made to the pre-stressing access platform. Whilst I acknowledge that longer term improvements are planned to the platform I intend to seek assurances from NGL that improvements have been made for the remaining works to be carried out in the current shutdown. I have raised an appropriate action on NGL and entered this onto ONR's issues database to ensure it can be adequately tracked to completion.
I was made aware that a load cell used to calibrate a pre-stressing jack is showing unreliable readings at low load levels despite having been recently calibrated. I am content that NGL has an adequate plan to address the anomaly and will deal with the matter in accordance with its own arrangements without detriment to the final declared tendon test loads.
I considered that the pre-stressing contractor's competency records can be improved by a greater focus on role definitions, with clear minimum training and qualification requirements identified for each role. I am content that a similar issue has been identified by an NGL quality audit and that this will be followed up by NGL in accordance with its own arrangements.
Based on my findings I judge that the following inspection rating against licence condition 28 (examination, inspection, maintenance and testing) is appropriate: Green.
There are no findings from this inspection that could significantly undermine nuclear safety and no change is necessary to the planned interventions and inspections at Hartlepool as a result.
I have raised two actions on station as a result of my intervention and will follow these up using the ONR issues database.
The findings of this intervention record and my subsequent assessment report will inform ONR's decision whether to issue consent for start-up of the reactor on completion of its 2016 shutdown.