The purpose of this intervention was to conduct an inspection of the arrangements in place at Hartlepool power station (HRA) for management of compliance with the Pressure Systems Safety Regulations (PSSR). The work was carried out as part of the planned intervention task sheet TS024 – “Through-Life Management of Flow Assisted Corrosion (FAC) and Pressure Systems Safety Regulation (PSSR) Compliance on AGR Sites”.
I carried out this inspection accompanied by an ONR Structural Integrity Inspector. The inspection took place on 14 and 15 February 2017 and involved discussions with staff from EDF Nuclear Generation (NGL) and Bureau Veritas (BV). BV are employed by NGL in the role of competent person, as defined within PSSR.
The objective of the inspection was to obtain information relating to NGL’s arrangements for managing compliance with PSSR, in order to identify any areas of relevant good practice, or shortfalls to our expectations. Particular emphasis was placed on the following:
I concentrated my intervention on items I judged important to nuclear safety, focussed upon Structural Integrity.
To assist with PSSR compliance, NGL have produced an internal code of practice “Safety Management of Pressure Systems”, BEG/SPEC/SHE/COP/036 (COP/036). The document identifies Regulations within PSSR and assigns responsibilities for complying with them. I have also used this document to assess the adequacy of arrangements implemented at Hartlepool.
The inspection reviewed the Written Schemes of Examination (WSE) and associated examination reports for selected systems, roles and responsibilities of key staff, process oversight and governance, I also sampled compliance arrangements against license conditions (LC) LC10 (training) to judge the adequacy of the arrangements in place.
The processes used by HRA to demonstrate their compliance and evidential arrangements against the requirements of COP/036 provide a clear method to ensure the appropriate processes are followed and suitable evidence is collated.
The PSSR Advisor demonstrated a good awareness of the key issues relating to pressure systems and compliance with PSSR, he was aware of the requirements of COP/036 and appeared to have suitable time to carry out his duties. It was also clear that he demonstrated a pro-active approach to implementing improvements to HRA’s PSSR compliance arrangements.
BV demonstrated awareness and understanding of their roles and responsibilities in order to manage compliance with PSSR at HRA. Sufficient resource is currently available to fulfil the current workload demands, but the demand is likely to increase significantly. NGL and BV need to ensure appropriate resource levels are maintained.
The System Engineers (SEs) present during the inspection demonstrated awareness of their responsibilities in accordance with COP/036, enabling compliance with PSSR. Station guidance drives maintenance routines to ensure the SEs formally review examination reports produced by the CP. There was evidence of good practice relating to working closely with the CP and understanding the outcome of the PSSR inspections.
Exclusions to WSEs, pressure system repairs & modifications and postponements of examination are being adequately dealt with by HRA, in line with my expectations for compliance with PSSR.
From the discussions during the inspection visit and sampled documentary evidence, I consider that HRA is able to adequately respond to imminent danger defects and repairs to pressure systems requested by the CP. HRA could demonstrate that the findings contained within a CP’s examination report were placed within their maintenance systems. A process for acting upon the additional recommendations/observations was identified.
HRA was able to clearly demonstrate that they are taking appropriate measures to prevent the reoccurrence of anomalies identified during the 2016 Reactor 2 outage. However, the site should consider whether an alternative approach to scheduling future PSSR examinations would be more effective and continued diligence is required to achieve consistency and accuracy in the content of CP examination reports.
In general, the areas visited during the plant tour appeared to be suitably maintained, with evidence of good housekeeping. I consider that the plant walk down demonstrated that HRA are actively managing PSSR inspection requirements and condition of their pressure systems.
From the sample reviewed, I consider that HRA have implemented an adequate process to ensure that relevant station staff attend the PSSR appropriate training. NGL should consider a review of training requirements to ensure that training is up to date and relevant. Additionally NGL should provide a suitable assessment for the Level 2 PSSR training course, that the time allocated to Level 2 training is sufficient and a suitable refresher course is available when needed.
HRA was able to clearly demonstrate that they are taking appropriate measures to prevent the reoccurrence of anomalies identified during the 2016 Reactor 2 outage, and the commitment of those present during the inspection to implement PSSR effectively was encouraging
No non-compliance issues relating to PSSR or COP/036 were identified at the time of the intervention, although minor areas for improvement were identified and communicated.
Based upon these inspection findings I judge that a Green rating is applicable at HRA for PSSR compliance.
A list of key findings and actions from this intervention has been provided to HRA for their consideration and resolution.
It is noted that the current PSSR development plan timescales at HRA are ambitious and will require continued effort in order for it to be effectively implemented. As a result a Level 4 regulatory issue, number 5182, has been raised to enable ONR to monitor progress made by HRA against their PSSR development plan and completion of actions raised.